Trueblood ex rel. Badayos v. Washington State Department of Social & Health Services
2016 U.S. App. LEXIS 8452
| 9th Cir. | 2016Background
- Washington DSHS is responsible for court-ordered competency evaluations and restorative services for pretrial detainees; most evaluations occur in jail or community settings.
- Plaintiffs alleged prolonged waits for evaluations and restoration (due to staffing, planning, travel, data shortfalls), causing serious mental-health harms (solitary confinement, self-harm, medication refusal).
- District court certified a class of persons ordered to receive competency evaluation or restoration services who were waiting in jail and for whom DSHS received the order.
- District court found due-process violations and entered a permanent injunction requiring in-jail competency evaluations (and certain hospital admissions) within seven days of a court order unless extended for clinical good cause.
- Washington appealed only the seven-day in-jail evaluation requirement; the Ninth Circuit reviewed constitutional standard, remedial scope, and the seven-day deadline.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether due process or Sixth Amendment governs claims about delay in competency evaluation | Trueblood: delay in evaluation implicates Fourteenth Amendment liberty interest; timely evaluation is required | DSHS: Sixth Amendment speedy-trial framework governs delay claims | Court: Fourteenth Amendment due-process reasonableness governs; Sixth Amendment is inapplicable |
| Whether the Constitution requires competency evaluations within seven days of a court order | Trueblood: seven days (or less) is necessary to protect liberty and prevent harm in jails | DSHS: seven-day rule is unduly strict given practical limits; state interest in accurate evaluations supports longer time | Court: evaluations must be timely and reasonably related to purpose, but seven days is not constitutionally required; district court abused discretion imposing seven-day bright line |
| Whether injunction’s timing metric should run from signing vs. DSHS receipt of order and whether non‑clinical delays warrant exceptions | Trueblood sought strict seven‑day compliance from signing | DSHS: practical receipt delays and non‑clinical impediments (counsel, interpreters) mean receipt should trigger timing and non‑clinical good‑cause exceptions should apply | Court: injunction improperly ran from signing and lacked non‑clinical good‑cause exceptions; remand to tailor injunction (consider state law and reasonableness) |
Key Cases Cited
- Drope v. Missouri, 420 U.S. 162 (1975) (defendant lacking competency may not be tried)
- Jackson v. Indiana, 406 U.S. 715 (1972) (duration and nature of commitment must bear a reasonable relation to its purpose)
- Youngberg v. Romeo, 457 U.S. 307 (1982) (due process balancing for detainee liberty and state interests in custodial care)
- Zadvydas v. Davis, 533 U.S. 678 (2001) (due process limits on detention duration; reasonableness framework)
- Oregon Advocacy Ctr. v. Mink, 322 F.3d 1101 (9th Cir. 2003) (pretrial detainees’ post‑incompetency jail waits violated due process)
- Barker v. Wingo, 407 U.S. 514 (1972) (speedy-trial balancing test)
- Katie A. ex rel. Ludin v. Los Angeles Cnty., 481 F.3d 1150 (9th Cir. 2007) (injunctions against state officers must not require more than constitutional or statutory duties)