Disability Law Center v. State
180 F. Supp. 3d 998
D. Utah2016Background
- Plaintiffs (Disability Law Center and three named incompetent criminal defendants) sued Utah state defendants under 42 U.S.C. § 1983 seeking declaratory and injunctive relief for prolonged pretrial detention of defendants found incompetent to stand trial while awaiting competency-restoration treatment at the Utah State Hospital (USH).
- Utah’s statutory scheme requires a court that finds a defendant incompetent to commit the defendant to the Department of Human Services for competency restoration at USH, which is the State’s sole designated facility for such treatment.
- USH forensic capacity is full; defendants ordered committed to USH are placed on a months-long waiting list and commonly remain incarcerated in county jails for many months before transfer.
- Plaintiffs allege jail conditions lack adequate mental-health treatment, often include protective custody or solitary confinement, and lead to deterioration of detainees’ mental health, undermining restoration prospects.
- Plaintiffs assert these practices violate substantive due process rights under the Fourteenth Amendment and Utah Constitution art. I, § 7; the State moved to dismiss for failure to state a claim.
- The district court denied the motion to dismiss, finding Plaintiffs plausibly alleged that the State’s prolonged detention and failure to provide adequate treatment after a competence ruling amount to punishment not reasonably related to legitimate governmental interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether incompetent pretrial detainees have a protected liberty interest against continued incarceration absent conviction | Incompetent detainees have a substantive due process liberty interest in freedom from incarceration absent conviction and in timely restoration | State disputes the asserted liberty interests and contends its interests (danger/flight risk, efficient restoration) justify continued detention | Court: Plaintiffs plausibly alleged the liberty interest; decline to decide additional interest in timely restoration at this stage |
| Whether holding incompetent detainees in jail pending transfer to state hospital constitutes punishment | Long delays, inadequate treatment, and harsh jail conditions frustrate evaluative/restorative purposes and amount to punishment | Continued detention is justified by preexisting reasons for detention (danger/flight) or by administrative/efficiency needs | Court: Allegations show detention is not reasonably related to legitimate goals and may be punitive; plausible substantive due process claim survives dismissal |
| Whether professional judgment shields detention conditions from constitutional scrutiny | If conditions reflect treatment decisions by qualified professionals, they are presumptively valid | State argues decisions reflect legitimate professional/administrative judgment | Court: Plaintiffs allege lack of professional restorative treatment and that delays are driven by lack of beds, so professional-judgment protection is not established at pleading stage |
| Applicability of Utah Constitution’s due process clause | Plaintiffs urge coextensive state protection under art. I, § 7 | State urges federal standard only | Court: Applies federal substantive due process analysis to conclude Plaintiffs also state a plausible Utah constitutional claim |
Key Cases Cited
- Jackson v. Indiana, 406 U.S. 715 (establishes that duration of pretrial confinement of incompetent defendants must bear reasonable relation to restorative/evaluative purpose)
- Bell v. Wolfish, 441 U.S. 520 (pretrial detainees may not be punished; restrictions must be reasonably related to legitimate governmental objectives)
- Youngberg v. Romeo, 457 U.S. 307 (confinement conditions for involuntarily committed persons are valid if based on professional judgment; liability only for substantial departures from accepted professional practice)
- Salerno v. United States, 481 U.S. 739 (recognizes substantive due process protection of liberty from government detention absent lawful justification)
- Foucha v. Louisiana, 504 U.S. 71 (freedom from physical restraint central to liberty interest)
- Zadvydas v. Davis, 533 U.S. 678 (liberty interest in freedom from indefinite detention)
- Or. Advocacy Ctr. v. Mink, 322 F.3d 1101 (9th Cir.) (holding that extended jail detention of incompetent pretrial detainees awaiting hospital transfer lacks legitimate state justification)