Case: C.P.X. v. Garcia
4:17-cv-00417 | U.S. District Court for the Southern District of Iowa
Filed Date: Nov. 27, 2017
Case Ongoing
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Case Summary
On November 27, 2017, three individuals seeking to represent a class of all persons confined to the Boys State Training School in Eldora, Iowa (the “School”), then or in the future, and who had a significant mental illness or emotional impairment, filed this suit in the U.S. District Court for the Southern District of Iowa. The School housed young boys incarcerated after adjudication as “juvenile delinquents” in state civil proceedings. The plaintiffs sued the Director of the Iowa Department of Human Services (DHS), the administrator of the division of Mental Health and Disability Services, and the Superintendent of the Boys State Training School under 42 U.S.C. § 1983. Represented by both Disability Rights’ Iowa (the state protection and advocacy system) and Children’s Rights Inc., the plaintiffs sought certification of their class as well as declaratory and injunctive relief. The case was assigned to Judge Stephanie M. Rose and Magistrate Judge Helen C. Adams.
The plaintiffs claimed that the defendants had improperly treated students with mental illnesses residing at the school. Such mistreatment included failing to provide care that addressed the mental health issues of the children, administering medication without adequate consent, and subjecting the children to solitary confinement and restraints as punishment for minor infractions.
In particular, the plaintiffs alleged that the defendants’ failure to provide adequate mental health treatment, inadequate oversight of and informed consent for administration of psychotropic medication, and unnecessary use of solitary confinement and mechanical restraints violated their substantive due process rights under the Fourteenth Amendment and the Eighth Amendment prohibition on cruel and unusual punishments. They also asserted that the defendants had violated the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act (Section 504) by denying them programming and services based on their mental impairments and by failing to reasonably accommodate them.
On January 26, 2018, the defendants filed a motion for summary judgment. On February 16, 2018, the plaintiffs filed an amended complaint. The amended complaint added K.N.X., a named plaintiff who had been administered psychotropic drugs without the consultation of his guardians. K.N.X. had also been taken off of the psychotropic drugs at the time of the filing of the amended complaint without the consent of either himself or his guardians and without receiving any information about the possible side effects of stopping medication.
On February 28, 2018, the defendants filed a motion for Independent Medical Examination (IME). The magistrate judge denied this motion exactly one month later, finding that the defendants had not established good cause for the examination because they had failed to show what was missing from the current medical record. The magistrate judge also concluded that it would be inappropriate for the defendants’ chosen doctor to perform the examinations because they were likely to be called as witnesses at the trial since they had previously examined one of the plaintiffs. On April 11, 2018, the defendants objected to the magistrate judge’s decision before the district court. On July 20, 2018, the district court overruled the defendants’ objections, holding that the magistrate judge’s decision was not clearly erroneous or contrary to law since the defendants had not put forward any reason that the current medical record was insufficient. 2018 WL 4701870.
Meanwhile, on June 28, 2018, the court denied the defendants’ motion for summary judgment. The defendants had argued that one of the named plaintiffs, G.R.X., had been discharged from the School and therefore lacked standing to pursue the action. The court concluded that the plaintiffs’ claims fell within the inherently transitory exception to the mootness doctrine and that his discharge from the School did not moot his claims, noting that G.R.X. had previously been discharged and then sent back to the School. 2018 WL 4701869. Nonetheless, on July 6, 2018, the plaintiffs filed an unopposed motion seeking to dismiss G.R.X. as a plaintiff, and on July 12, 2018, the court granted the motion.
On August 3, 2018, the plaintiffs filed a motion to certify the putative class. They defined the class as all boys confined to the School since the filing of the complaint, now, or in the future, and who had a mental illness or emotional impairment as evidenced through either receiving psychotropic medications or having a diagnosis for a mental health disorder specified in the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition (“DSM-V”), or the Fourth Edition in effect prior to 2013 (“DSM-IV”), as determined by a mental health professional.
On November 30, 2018, while the motion for class certification was pending, the defendants filed a second motion for summary judgment. The court granted in part and denied in part this motion on February 19, 2019.
The district court held:
- The Fourteenth Amendment due process clause, rather than the Eighth Amendment, applied to the plaintiffs’ claims given the non-penal and non-criminal nature of Iowa juvenile delinquency proceedings. The court therefore granted summary judgment to the defendants as to the plaintiffs’ Eighth Amendment claims.
- Genuine issue of material fact existed as to whether mental health care provided to students at the school was inadequate, precluding summary judgment on the plaintiffs’ due process claim. While the court agreed with the defendants’ broad proposition that the plaintiffs were not entitled to optimal mental health care, the court did not grant summary judgment because plaintiffs asserted that the defendants had failed to provide “minimally adequate” mental health care.
- Genuine issue of material fact also existed as to whether the defendants acted appropriately based on their knowledge of various deficiencies with the mental health care at school for juveniles adjudicated delinquent, further precluding summary judgment on due process claim.
- The plaintiffs sufficiently alleged a disability, as would be required to support ADA and Rehabilitation Act claims.
- A genuine issue of material fact as to whether students were denied educational opportunities available to other students without disabilities precluded summary judgment on the ADA and Rehabilitation Act claims.
Lastly, the court rejected the defendants’ argument that the relief sought by the plaintiffs required dismissal of their claims because it would require a “significant infusion of state resources in violation of the Eleventh Amendment.” The fact that some of the relief requested by the plaintiffs would require ancillary costs was not enough of a reason to render it unconstitutional. 361 F.Supp.3d 822.
On March 13, 2019, the court granted the plaintiffs’ motion to certify their class, certifying a class of “all boys confined to the School since the filing of the Complaint, now, or in the future, who have received psychotropic medications or a diagnosis for a mental health disorder specified in the Diagnostic and Statistical Manual of Mental Disorders, Fifth Edition (“DSM-V”) or Fourth Edition (“DSM-IV”), as determined by a mental health professional.” 330 F.R.D. 197.
On March 30, 2020, following a bench trial, the court rendered judgment in the case. The court found in the plaintiffs' favor as to count I (substantive due process, Fourteenth Amendment Claims) and in the favor of the defendants on Counts III (ADA Claim) and IV (Rehabilitation Act Claim).
First, the court addressed the defendants’ asserted affirmative defense that the plaintiffs had not exhausted all administrative remedies available to them as required by the Prison Litigation Reform Act (PLRA). The court found that the plaintiffs had properly exhausted their Fourteenth Amendment claim, but not their ADA and Rehabilitation Act Claim.
The court agreed that the defendants had violated the Fourteenth Amendment after taking into account the evidence the School, by failing to provide adequate mental health care to the students, had created a substantial risk of serious harm to the Class. The lack of psychotherapy was key in this determination because it “should be the ‘primary treatment modality’ for the mental health disorders common at institutions like the School” and yet it was nonexistent. Furthermore the School was deliberately indifferent to this need as evidenced by their ignoring of previous advice that their mental health treatments were insufficient. Lack of funding was not a valid excuse for this behavior and no meaningful steps had been taken to address these failures. The court emphasized the following failures to : (1) formulate mental health treatment plans; (2) provide adequate crisis services by offering the therapy needed to assess the underlying causes of students’ self-harming or suicidal ideations; (3) maintain confidential mental health records; (4) provide adequate discharge planning; and (5) properly oversee the mental health programming at the School, be that through a qualified mental health authority or other structure. Based upon these findings, the court determined that the School’s mental health care provisions violated the Class’s substantive due process rights.
The court separately considered the plaintiffs’ solitary confinement claim which asserted that the School’s use of isolation and restraints was employed excessively and as a means of punishment. The court agreed with the plaintiffs that it violated their due process rights under the anti-punishment standard of Bell v. Wolfish and that the defendants were deliberately indifferent to the substantial risk of serious harm the practices caused the class. The court also found that the defendants’ use of the wrap, a mechanical restraining device, also violated the Fourteenth Amendment for similar reasons.
As to the ADA and RA claims, the court determined that the plaintiffs had failed to establish the defendants’ liability because of their inability to satisfy the third Olmstead factor. This factor required the plaintiffs to offer a reasonable accommodation. Here, though they sought elimination of isolation and restraints to treat students with mental health illnesses, they had not shown that this could be reasonably accommodated.
The court ordered injunctive relief including the following:
- Within 45 days, the defendants would submit a plan to the court that would address the mental health are deficiencies of the School;
- The School would only employ isolation in situations where a student’s behavior posed a serious or substantial risk of physical harm;
- The School would increase the privileges of students who were subject to administrative segregation;
- The School would not use the wrap and would seek court approval for use of mechanical restraints;
- The School would provide training to their staff focused on safety of both the students and the staff.
- The court also appointed a monitor to oversee the implementation of the injunctive relief. The monitor would last until the School was in substantial compliance with the remedial plan for two full years. 450 F.Supp.3d 854.
On April 10, 2020, the plaintiffs filed a motion for attorneys fees and expenses. On January 7, 2021, the court granted in part the plaintiffs' motion. The court found it appropriate to reduce the amount of fees by $10,000, citing the defendants’ argument that some of the fees billed to paralegals were purely administrative and clerical and did not require the professional expertise of a paralegal and therefore should not be subject to a paralegal-level rate. In total, the plaintiffs were awarded $4,540,762.90 in attorneys fees and $390,363.05 in expenses. 2021 WL 302754.
On April 22, 2020, the court appointed Dr. Kelly Dedel as monitor.
On January 27, 2021, the defendants filed a notice of appeal with the U.S. Court of Appeals for the Eighth Circuit of the court’s award of attorneys fees.
On February 14, 2021, the monitor filed their initial report in which they found that the defendants had substantially or partially complied with all applicable provisions.
On July 7, 2021, the monitor filed an interim report that updated its findings. The monitor concluded that the new programs and practices for addressing mental health care were complete and appropriate. But, the monitor noted that their efficacy was undercut by the increase in youth violence at the School. The monitor urged that the increase in violence demanded action and that if not properly addressed the violence would prevent the success of the new programs and policies.
On November 5, 2021, a second comprehensive report was filed with the court. The monitor found non-compliance only in regards to multi-sensory de-escalation tools and spaces. The defendants had initially successfully created a multi-sensory de-escalation room (MSDR) that was frequently used. When the room had to be relocated because of a Heating, Ventilation, and Air Conditioning (HVAC) project in the room, most of the tools had been misplaced or broken which led to underutilization.
On December 15, 2021, the court of appeals affirmed the district court’s decision awarding fees and expenses. 2021 WL 5917780.
On December 27, 2022, the monitor filed a third report. The monitor reported that the School had substantially or partially complied with all relevant provisions.
As of November 8, 2023, this case was ongoing.
Summary Authors
Rhea Sharma (11/21/2023)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6542363/parties/cpx-v-garcia/
Driscoll, Whitney Elizabeth (Iowa)
Berg, Nicholas M. (Iowa)
Farrell, Timothy R. (Iowa)
Dedel, Kelly (Iowa)
Dixit, Anagha (Iowa)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/6542363/cpx-v-garcia/
Last updated April 14, 2026, 5:41 a.m.
Case Details
State / Territory:
Case Type(s):
Healthcare Access and Reproductive Issues
Key Dates
Filing Date: Nov. 27, 2017
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
All persons who are confined to the Boys State Training School in Eldora, Iowa, now or in the future, and who have a significant mental illness or emotional impairment, as determined by a mental health professional qualified under the laws and regulations of Iowa
Plaintiff Type(s):
Attorney Organizations:
NDRN/Protection & Advocacy Organizations
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
State
Boys State Training School
Division of Mental Health and Disability Services
Iowa Department of Human Services
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
Section 504 (Rehabilitation Act), 29 U.S.C. § 701
Constitutional Clause(s):
Due Process: Substantive Due Process
Other Dockets:
Southern District of Iowa 4:17-cv-00417
U.S. Court of Appeals for the Eighth Circuit 21-01206
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Granted:
Injunction / Injunctive-like Settlement
Source of Relief:
Content of Injunction:
Amount Defendant Pays: $4,931,125.95
Issues
General/Misc.:
Informed consent/involuntary medication
Parents (visitation, involvement)
Disability and Disability Rights:
Intellectual/developmental disability, unspecified
Discrimination Basis:
Disability (inc. reasonable accommodations)
Jails, Prisons, Detention Centers, and Other Institutions:
Solitary confinement/Supermax (conditions or process)
Case Summary of C.P.X. v. Garcia, Civil Rights Litig. Clearinghouse, http://www.dev.clearinghouse.net/case/43967/ (last updated 11/21/2023).