Martarella v. Kelley
349 F. Supp. 575, 1972 U.S. Dist. LEXIS 11566 (1972)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
When the state, acting under its parens patriae power, confines non-criminal children, it has a constitutional obligation to provide them with adequate treatment as a quid pro quo for the deprivation of their liberty. The failure to provide such treatment, particularly for long-term detainees, violates the Due Process Clause.
Facts:
- Robert Martarella and other plaintiffs were children designated as 'Persons In Need of Supervision' (PINS) under New York law for non-criminal acts like truancy, running away, or being 'ungovernable'.
- The City of New York detained these PINS children in maximum-security juvenile centers: Spofford, Manida, and Zerega.
- These facilities also housed juvenile delinquents (JDs), who were children charged with acts that would be considered crimes if committed by an adult.
- The centers were described as 'prison-like,' with high walls, constantly locked metal doors, institutional uniforms, and regimented routines such as marching in silent lines.
- The physical conditions, especially at Manida and Zerega, were severely deficient; Manida was dilapidated and depressing, and Zerega consisted of sinking metal structures.
- While detention was intended to be temporary, a significant number of children were held for extended periods, some for over 100 days, due to difficulties in finding permanent placements.
- The centers suffered from chronic staff shortages, including an insufficient number of counselors, caseworkers, and psychiatrists, and the existing staff lacked adequate training to provide therapeutic services.
Procedural Posture:
- Robert Martarella and other plaintiffs filed a civil rights class action in the United States District Court for the Southern District of New York.
- The plaintiffs sought a declaration that their detention violated their constitutional rights and requested injunctive relief against Family Court Judges and city officials operating the juvenile centers.
- The plaintiffs moved for a preliminary injunction.
- The court consolidated the hearing on the preliminary injunction with a full trial on the merits of the case.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the secure detention of non-criminal children, classified as 'Persons In Need of Supervision' (PINS), in facilities with punitive conditions, inadequate rehabilitative treatment, and alongside juvenile delinquents, violate their constitutional rights to due process, equal protection, and freedom from cruel and unusual punishment?
Opinions:
Majority - Lasker, J.
Yes, in part, and no, in part. The detention of PINS children violates the Eighth Amendment where physical conditions are unconstitutionally poor (Manida) and violates due process where long-term detainees are not provided with adequate treatment. However, housing PINS children with juvenile delinquents (JDs) does not violate the Equal Protection Clause, and the physical conditions at one facility (Spofford) are constitutionally acceptable. The court established that when the state acts as 'parens patriae' to confine individuals not convicted of a crime, it must provide adequate treatment. This 'right to treatment' is the constitutional quid pro quo for the deprivation of liberty. For children held in long-term detention, the lack of a 'bona fide effort' to provide treatment—evidenced by staff shortages, inadequate training, and a punitive rather than therapeutic environment—violates due process. While the program may be minimally acceptable for short-term detainees, it is unconstitutional for long-termers. Regarding the equal protection claim, the court found a rational basis for housing PINS with JDs while separating neglected children from JDs. A PINS petition is based on the child's own misbehavior (albeit non-criminal), whereas a neglect petition concerns the parent's failure. This factual distinction allows the state to treat the two classes of non-criminal children differently. Finally, the court held that the physical conditions at Manida were so deplorable as to constitute cruel and unusual punishment under the Eighth Amendment. However, the conditions at Spofford, while not ideal, were not so hazardous as to be unconstitutional, and the claim regarding Zerega was moot as the facility had closed.
Analysis:
This case is a foundational decision in juvenile justice, firmly establishing a constitutional 'right to treatment' for non-criminally detained youths. It solidifies the principle that the state's parens patriae power is not a license for mere warehousing but carries a corresponding duty to provide care and rehabilitation. The decision's distinction between the constitutional requirements for short-term versus long-term detention introduced a durational element into the due process analysis, influencing subsequent litigation regarding the rights of individuals in state custody, including those in mental health facilities. The ruling put pressure on states to either improve conditions and treatment programs in juvenile facilities or find less restrictive, community-based alternatives.
