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Ricky Wyatt v. Virginia Rogers, United States of America, Amicus Curiae
United States District Court for the Middle District of Alabama
985 F. Supp. 1356 (1997)
Spanning from 1970 to 2004, the district court oversaw the implementation of judicially established standards of care for institutionalized patients with mental illness or intellectual disabilities housed in Alabama. Ricky Wyatt (plaintiff) represented the class in a four-phase suit against Alabama state officials (defendants) for failure to provide adequate care. In 1971, the court ordered state officials to comply with certain minimum standards of care, dubbed the Wyatt standards. In 1986, the court approved a proposed settlement, which (1) removed active judicial supervision of the state-run facilities but required that the state reach substantial compliance of the Wyatt standards; (2) required the state to obtain accreditation and certification at its facilities; and (3) required community placement of individuals. Additionally, the settlement required establishment of patient advocates and quality-assurance systems, resulting in the creation of the Wyatt Consultant Committee, which provided expert guidance for compliance; kept the class attorney apprised of state progress; and acted as mediator. For any modifications to the standards, the court ordered the parties to get input from class members, public interest organizations, former patients, family members, and caregivers so that the best interests of the class were protected. The final and current phase of litigation began in 1991, when state officials filed a motion for a judicial finding of compliance and termination. In 1993, Wyatt moved for further relief based on the state’s failure to comply with the 1986 order or American with Disabilities Act (ADA) of 1990. Trial proceeded on the state’s 1991 motion and Wyatt’s 1993 motion. During these proceedings, the court discovered substantial abuse and lack of compliance with standards at the Eufaula Adolescence Center, which housed children suffering from mental illness or emotional disturbance. By 1995, the state had still not instituted a transitional plan for providing less restrictive services, and the children were kept in unsafe conditions due to gang activity; subjected to physical, emotional, and sexual abuse; subjected to improper restraints; and the facility failed to provide individualized therapeutic treatment. The state was aware of these conditions but did not take quick action to protect the children. As a result, the court issued an injunction to immediately correct all issues; however, the center was subsequently closed. In 2004, the court found that the state had finally complied with the entire 1986 settlement agreement.
Rule of Law
Holding and Reasoning (Thompson, C.J.)
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