John Doe 4 v. Shenandoah Valley Juvenile, 985 F.3d 327

Background:

Class action by unaccompanied alien children (UACs) detained at Shenandoah Valley Juvenile Center (SVJC) challenging adequacy of mental-health care and punitive practices that allegedly retraumatize residents.
SVJC is a secure juvenile facility that provides weekly one-on-one counseling, short group sessions, and periodic psychiatrist visits (medication management only); it also uses restraints, room confinement, and a restraint chair for discipline.
Many UACs at SVJC have severe trauma histories; record shows numerous self-harm incidents and clinicians sometimes recommended residential treatment that SVJC lacked capacity to provide.
District court granted summary judgment to the Commission on the inadequate-mental-health-care claim, applying the deliberate-indifference standard and excluding some expert testimony (including on trauma-informed care).
Fourth Circuit reversed and remanded, holding the district court applied the wrong constitutional standard and improperly excluded evidence relevant under the correct standard.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing / redressability	SVJC’s policies cause harm; injunction against SVJC would redress injuries	Absent ORR as defendant, relief cannot be effective because ORR controls placement/approval	Plaintiffs have standing; SVJC controls day-to-day care and ORR’s approval is not an independent barrier to redress
Governing constitutional standard for mental-health care	Youngberg professional-judgment standard (liability when treatment substantially departs from accepted professional judgment)	Deliberate-indifference standard (objective serious need + subjective knowledge and disregard)	Youngberg applies to UACs in SVJC; courts must assess substantial departures from professional standards rather than deliberate indifference
Relevance/admissibility of trauma-informed-care evidence	Trauma-informed care is an accepted, relevant professional framework for treating traumatized youth and bears on adequacy of care	Trauma-informed care is aspirational/not a constitutional minimum; expert opinions on it are irrelevant	Trauma-informed care is part of the relevant landscape; excluding expert evidence on it was erroneous and trial court must consider it under Youngberg
Summary judgment on adequacy of care	Material disputes exist (e.g., failure to provide residential treatment, punitive responses, frequency/quality of therapy)	SVJC provided evaluations, counseling, medications, and attempted transfers; no constitutional violation under deliberate-indifference analysis	Summary judgment was improper because the district court applied the wrong standard, misread record, and ignored evidence bearing on whether professional judgment was exercised; case remanded

Key Cases Cited

Youngberg v. Romeo, 457 U.S. 307 (U.S. 1982) (establishes professional-judgment standard for care of involuntarily committed persons)
Patten v. Nichols, 274 F.3d 829 (4th Cir. 2001) (discusses when Youngberg applies vs. deliberate indifference)
De’lonta v. Angelone, 330 F.3d 630 (4th Cir. 2003) (prison medical-policy reliance can show lack of individualized professional judgment)
De’lonta v. Johnson, 708 F.3d 520 (4th Cir. 2013) (treatment must be adequate under accepted standards; some care does not necessarily satisfy constitutional requirements)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard for prison officials)
DeShaney v. Winnebago Cnty. Dep’t of Soc. Servs., 489 U.S. 189 (U.S. 1989) (state’s duty to provide basic needs when it holds a person in custody)
Flores v. Sessions, 862 F.3d 863 (9th Cir. 2017) (discusses ORR duties and Flores settlement as floor for treatment of detained minors)
Bennett v. Spear, 520 U.S. 154 (U.S. 1997) (third-party decisionmaking and redressability principles)
Matherly v. Andrews, 859 F.3d 264 (4th Cir. 2017) (applies Youngberg to involuntary commitment within a prison program)
Bowring v. Godwin, 551 F.2d 44 (4th Cir. 1977) (recognizes right to psychiatric care comparable to physical medical care)