Case: Michigan Protection & Advocacy Service, Inc. v. Caruso
5:05-cv-00128 | U.S. District Court for the Western District of Michigan
Filed Date: Sept. 14, 2005
Closed Date: 2011
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Case Summary
On September 14, 2005, the Michigan Protection and Advocacy Service (MPAS) filed this complaint on behalf of youths aged 22 and younger with mental illnesses incarcerated in the Michigan Youth Correctional Facility (MYCF). The MYCF, a maximum security prison for adolescent males convicted as adults, was privately operated by GEO Group, Inc. In October of 2005, approximately two weeks after the complaint was filed, the MYCF facility was closed and all the incarcerated youths were moved to other Michigan Department of Correction (MDOC) facilities. MPAS, however, claimed all the illegal conditions of confinement described below continued to exist.
The complaint listed three areas of concern.
First, because the MYC facility had the highest security level, there were fewer educational and rehabilitation programs available. After MYCF closed, MPAS claimed that the youths with mental illnesses still had limited access to appropriate educational programs, in violation of the Individuals with Disabilities Education Act (IDEA) 20 U.S.C. § 1401.
Second, MPAS also claimed that the MDOC screening and treatment procedures for youths with mental illnesses were inadequate. MPAS argued that youths with diagnosed mental illnesses were instead classified as malingering and manipulative and were more likely to be placed in disciplinary and administrative segregation and to spend longer amounts of time there than the other youths in violation of Title II of the Americans with Disabilities Act (ADA), 41 U.S.C. § 12132 and Section 504 of the Rehabilitation Act of 1973 (504), 29 U.S.C. § 794.
Finally, MPAS claimed that the social and sensory deprivation conditions of isolation exacerbated existing mental illnesses, and sometimes caused the development of mental illnesses in youths who were previously healthy. They claimed that this violated the youths' Eighth Amendment protection against cruel and unusual punishment. Lastly MPAS contends that MDOC violated the youths' Fourteenth Amendment due process rights by imposing punishments without determining if they should be held accountable for their actions.
MPAS sought declaratory judgment and permanent injunction to resolve the above issues.
Starting in September of 2006, the the parties began developing an action plan based on a series of settlement talks mediated by Chief Judge Paul L. Maloney and in July of 2008 submitted a implementation plan to the Court which was not made public.
As understood from the stipulation for stay document, one aspect of the plan was the implementation of monitors in 2007 to oversee the defendant’s resolution of the issues raised in the plaintiff’s complaint. These included better screening procedures to identify prisoners with mental illnesses, not placing prisoners in administrative segregation or placing them there for shorter periods, and training the staff on mental illnesses.
In October, 2008, the Court granted the defendant's partial motion for summary judgment related to a question of providing special education. Federal law required MDOC to provide special education services to prisoners until they reached the age of 22. The Court granted the partial motion for summary judgment to clarify that the Michigan Mandatory Special Education Act, which would have extended access to special education until the age of 27, did not apply to prisoners because MDOC was not a "public agency" as understood by the Act.
The matter was stayed until August 2009, then again until December 2010, and finally until June 2011 to allow time to implement the changes.
In June, 2011, both parties agreed that the complaint should be dismissed as the issues had been resolved.
Summary Authors
Amanda Kenner (2/21/2017)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4694503/parties/michigan-protection-advocacy-service-inc-v-caruso/
Carmody, Ellen S. (Michigan)
Enslen, Richard Alan (Michigan)
Cecil, Thomas G. (Michigan)
Cody, Mark A. (Michigan)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/4694503/michigan-protection-advocacy-service-inc-v-caruso/
Last updated March 30, 2026, 4:31 a.m.
Case Details
State / Territory:
Case Type(s):
Healthcare Access and Reproductive Issues
Special Collection(s):
Key Dates
Filing Date: Sept. 14, 2005
Closing Date: 2011
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Michigan Protection and Advocacy Service, a private non-profit with statutory authority to investigate and protect the rights of youths with disabilities or mental illnesses.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
State
Patricia L. Caruso
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Indv. w/ Disab. Educ. Act (IDEA), Educ. of All Handcpd. Children Act , 20 U.S.C. § 1400
Constitutional Clause(s):
Other Dockets:
Western District of Michigan 5:05-cv-00128
Available Documents:
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Granted:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Issues
General/Misc.:
Disability and Disability Rights:
Discrimination Basis:
Disability (inc. reasonable accommodations)
Jails, Prisons, Detention Centers, and Other Institutions:
Solitary confinement/Supermax (conditions or process)
Medical/Mental Health Care:
Case Summary of Michigan Protection & Advocacy Service, Inc. v. Caruso, Civil Rights Litig. Clearinghouse, http://www.dev.clearinghouse.net/case/14259/ (last updated 2/21/2017).