## Facts

- A longstanding class action challenged conditions and treatment in Alabama’s public mental health and intellectual-disability system.
- Early orders established “Wyatt standards” requiring (1) a humane environment, (2) sufficient qualified staff, and (3) individualized treatment plans.
- A 1986 consent decree ended day-to-day court supervision but required “substantial compliance” with the Wyatt standards, accreditation/certification efforts, greater community placement, and oversight mechanisms (including an expert consultant committee and advocacy/quality-assurance measures).
- In 1991, state officials moved for a finding of compliance and termination of the litigation.
- In 1993, plaintiffs sought further relief, asserting continued noncompliance and violations of the Americans with Disabilities Act (ADA), including failures to provide appropriate community-based services.
- After an extensive evidentiary record developed through a multi-week summary proceeding, conditions at the Eufaula Adolescent Center were highlighted: unsafe conditions tied to gang activity, physical/emotional/sexual abuse, improper restraints, lack of individualized therapeutic treatment, and inadequate transition planning to less restrictive services.
- The state had notice of serious problems at Eufaula but did not promptly remedy them; the court issued injunctive relief and the facility ultimately closed.

## Issues

1. Whether the state had achieved substantial compliance with the 1986 consent decree and treatment standards such that the case should be terminated.
2. Whether plaintiffs were entitled to additional equitable relief, including remedies informed by ADA obligations to provide services in appropriate, integrated settings.

## Decision

- Denied defendants’ motion for a finding of compliance and termination of the litigation.
- Granted plaintiffs further equitable relief in substantial part, ordering remedial measures to address ongoing deficiencies, including those exemplified by conditions at Eufaula.
- Limited or declined certain enforcement aspects based on earlier procedural rulings governing how decree enforcement was to be pursued.

## Legal Principles

- Institutionalized persons are entitled to minimally adequate treatment and humane conditions; core requirements include a humane environment, adequate qualified staffing, and individualized treatment planning.
- Consent decrees in institutional-reform cases may be enforced and supervised until defendants demonstrate substantial compliance and durable correction of the violations the decree addressed.
- Termination is improper where serious, ongoing deficiencies show the decree’s objectives have not been achieved in practice.
- The ADA imposes independent duties on public entities relevant to placement and service delivery, supporting movement toward appropriate community-based services and away from unnecessary institutionalization.
- Courts may issue broad equitable remedies when needed to correct persistent systemic failures shown by a developed evidentiary record.

## Conclusion

The court found that Alabama had not achieved substantial compliance with the 1986 consent decree and treatment standards, denied termination, and ordered further remedial relief to address continuing unsafe and clinically inadequate conditions and to improve access to appropriate, less restrictive services consistent with federal disability law.


Wyatt by & through Rawlins v. Rogers, 985 F. Supp. 1356 (M.D. Ala. 1997)