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Trueblood v. Washington State Department of Social And Health Services

822 F.3d 1037 (2016)

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Trueblood v. Washington State Department of Social And Health Services

United States Court of Appeals for the Ninth Circuit
822 F.3d 1037 (2016)

RW

Facts

Defendants suspected of being mentally incompetent to stand trial on criminal charges typically were jailed while awaiting their competence evaluations or competence-restoring medical treatment. Cassie Trueblood, as the next friend of a mentally incompetent detainee, Ara Badayos (plaintiff), filed a 42 U.S.C. § 1983 class-action suit against the Washington State Department of Social and Health Services (DSHS). Trueblood alleged that DSHS left many detainees in jail for far longer than the seven to 14 days that a recent state statute had set as the aspirational time frame for conducting competence evaluations and providing restorative treatment. Based on bench-trial evidence, the district court found that DSHS already provided most evaluations and treatment within seven days and that seven days was a feasible time frame for providing all evaluations and treatment. The court ruled that delaying any evaluation or treatment more than seven days unreasonably deprived a detainee of his constitutionally protected liberty interest in freedom from incarceration. The court issued an injunction requiring DSHS to transfer any such unreasonably detained detainee from jail to DSHS facilities. DSHS appealed to the Ninth Circuit.

Rule of Law

Issue

Holding and Reasoning (McKeown, J.)

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