Reed v. Palmer
United States Court of Appeals for the Seventh Circuit
906 F.3d 540 (2018)
- Written by Caitlinn Raimo, JD
Facts
In 2014, the State of Iowa closed the Iowa Girls State Training School in Toledo. Charles Palmer (defendant), director of the Iowa Department of Human Services, contracted with the State of Wisconsin to use the Wisconsin Girls State Training School (Copper Lake). Paige Ray-Cluney and Laura Reed (plaintiffs) were juveniles placed at Copper Lake in 2015. Ray-Cluney and Reed alleged that Copper Lake had a history of inhumane treatment of juveniles. During their stays, Ray-Cluney and Reed were subjected to periods of isolation of up to 22 hours per day during which they were not permitted to speak to others, given little to no education, and subjected to physical abuse. Ray-Cluney and Reed sued Palmer and Wisconsin officials actively involved with Copper Lake (defendants), alleging in part violations of the Fourth, Eighth, and Fourteenth Amendments. Although Palmer received and oversaw complaints about juveniles housed at Copper Lake, he was not involved in the day-to-day operations and control of the facility. Palmer moved to dismiss, alleging qualified immunity. The district court found in favor of Palmer because no law clearly established what the Constitution required of officials in Palmer’s position under similar circumstances. Ray-Cluney and Reed appealed.
Rule of Law
Issue
Holding and Reasoning (Flaum, J.)
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