Trueblood v. Washington State Department of Social & Health Services
101 F. Supp. 3d 1010
W.D. Wash.2015Background
- Plaintiffs seek an order requiring Defendants to provide timely competency evaluation and restoration services to class members detained in jails awaiting court-ordered services.
- Court previously held seven-day wait times constitutional and longer waits suspect, and held a seven-day bench trial (Mar. 16–25, 2015) to determine the outer boundary and remedy.
- Summary findings allege Washington’s failure to provide seven-day competency services violates substantive and procedural due process and that jails are unsuitable for mentally ill individuals awaiting services.
- DSHS funding, bed space, and staffing shortages are identified as primary barriers, with further organizational and procedural barriers across hospitals, courts, and counties.
- Class is defined as all persons charged with crimes in Washington who are ordered to receive competency services, are awaiting those services in jail, and for whom DSHS receives the court order; DRW represents the class.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prolonged pretrial detention for competency services violates due process | Pechman/DRW contend seven days is constitutionally required. | DSHS argues delays are due to resource and system constraints, not per se unconstitutional. | Yes; seven days is the maximum justifiable period absent good cause. |
| Whether DRW and next friends have standing | DRW has standing to pursue injunctive relief for rights of class members. | Defendants challenge lack of standing, if any. | DRW and next friends have standing to seek injunctive relief and declaratory relief. |
| Whether a permanent injunction is appropriate to remedy the constitutional violation | Court should enjoin ongoing delays and ensure seven-day competency services with monitoring. | Defendants should be allowed time to improve, but ongoing injunction is unnecessary or premature. | Yes; permanent injunction with seven-day commitments and monitoring is warranted. |
| Whether the seven-day standard is achievable and appropriate given system barriers | System can meet seven days with funding and planning improvements. | Improvements require time and resources; seven days may be aspirational without reform. | Seven days is reasonable and achievable with proper resources and management; long-term plan required. |
Key Cases Cited
- Mink v. City of Portland, 322 F.3d 1101 (9th Cir. 2003) (due process rights of incapacitated defendants; right to restorative treatment)
- Ohlinger v. Watson, 652 F.2d 775 (9th Cir. 1981) (individualized treatment rights; constitutional basis for rehabilitation)
- Jackson v. Indiana, 406 U.S. 715 (1972) (due process requires confinement bear reasonable relation to purpose)
- Bell v. Wolfish, 441 U.S. 520 (1979) (pretrial detainees cannot be punished; due process constraints on confinement)
- Lopez-Valenzuela v. Arpaio, 770 F.3d 772 (9th Cir. 2014) (en banc; due process in pretrial detention; balancing interests)
- Or. Advocacy Ctr. v. Mink, 322 F.3d 1101 (9th Cir. 2003) (authority supporting DRW standing and rights of disability advocates)
- In re Lamb, 173 Wash.2d 173 (2011) (state standing and authority for rights-based actions in disability context)