Summary of Argument

The district court erred in concluding that a trauma-informed approach to mental health care for detained children is merely aspirational, rather than reflecting the constitutionally required standard of professional care. In fact, a trauma-informed approach has been widely accepted and adopted as the standard of care in this setting. A trauma-informed approach is critical for child detainees, and failing to implement such an approach can both permanently injure the children who are in the states’ care and erode the public’s trust in the legitimacy and integrity of the legal system, thereby harming public safety.

Plaintiffs in this case have been harmed in numerous ways because Shenandoah Valley Juvenile Center (“SVJC”) has egregiously and repeatedly departed from accepted professional norms—including failing to provide adequate mental health treatment to children in its care with known mental health issues and using punitive measures including lengthy solitary confinement. Yet the district court erroneously rejected Plaintiffs’ claim that they failed to receive adequate mental health care by applying the wrong constitutional standard. Rather than using the “deliberate indifference” standard, the court should have applied the professional judgment standard set forth in Youngberg v. Romeo, 457 U.S. 307 (1982). A trauma-informed approach represents the accepted standard of professional judgment under Youngberg, and the SVJC violated Plaintiffs’ rights by failing to adopt it. Under the correct constitutional standard, there are clearly genuine issues of material fact, and this Court should remand the case to the district court.

Summary of Argument

The district court's determination that a trauma-informed approach to mental healthcare for detained children constitutes an aspirational goal rather than a constitutionally mandated standard of professional care is erroneous. This approach has gained widespread acceptance and adoption as the standard of care in this specific setting. A trauma-informed approach is crucial for child detainees, and its absence can result in permanent harm to children under state care and erode public confidence in the legitimacy and integrity of the legal system, thereby negatively impacting public safety.

The plaintiffs in this case have suffered significant harm due to Shenandoah Valley Juvenile Center's (SVJC) repeated and egregious departures from accepted professional norms. These departures include a failure to provide adequate mental health treatment to children in its care who have known mental health issues and the use of punitive measures such as prolonged solitary confinement. The district court erred in dismissing the plaintiffs' claim of inadequate mental health care by applying an incorrect constitutional standard. Instead of the "deliberate indifference" standard, the court should have employed the professional judgment standard. A trauma-informed approach represents the accepted standard of professional judgment under Youngberg, and the SVJC violated the plaintiffs' rights by failing to adopt it. Under the correct constitutional standard, genuine issues of material fact exist, warranting this Court to remand the case to the district court.

Summary of Argument

The district court erred in concluding that a trauma-informed approach to mental health care for detained children is merely aspirational. The court should have applied the professional judgment standard set forth in Youngberg v. Romeo, 457 U.S. 307 (1982). This standard requires facilities like SVJC to provide care that meets the accepted professional norms. A trauma-informed approach is widely accepted as the standard of care in juvenile detention settings.

The district court’s failure to apply the proper standard resulted in the erroneous dismissal of the plaintiffs’ claims. The plaintiffs were harmed by SVJC’s failure to provide adequate mental health treatment and its use of punitive measures. SVJC’s departure from accepted professional norms, including the lack of a trauma-informed approach, violated the plaintiffs’ rights. Because genuine issues of material fact exist, the case should be remanded to the district court for further consideration.

Summary of Argument

The district court made a mistake in saying that a trauma-informed approach to mental health care for detained children is just an idea, not a necessary standard of care. Actually, this approach is widely accepted and used as the standard of care for children in these situations.

A trauma-informed approach is extremely important for kids in detention. Without it, these children can be seriously harmed both mentally and physically. Plus, failing to use this approach can also make people lose trust in the legal system, which can make everyone less safe.

The plaintiffs in this case have been hurt in many ways because the Shenandoah Valley Juvenile Center (SVJC) has repeatedly ignored accepted professional standards. This includes not giving proper mental health care to children with known problems and using harsh punishments like long periods of solitary confinement. The district court incorrectly rejected the plaintiffs' claim that they didn't get good mental health care by using the wrong legal standard. Instead of using the “deliberate indifference” standard, they should have used the “professional judgment” standard set out in a previous case called Youngberg v. Romeo.

A trauma-informed approach is the accepted standard of professional judgment, and the SVJC broke the law by not adopting it. Using the correct legal standard, it's clear that there are important questions about what happened, and the case should be sent back to the district court for them to look into it further.

Summary of Argument

The court made a mistake when it said that trauma-informed mental health care is just a wish. This way of helping should actually be the standard.

In this case, the kids were treated very poorly. The prison they were in didn't give them the help they needed and even used punishments like solitary confinement.

The court should have used a different rule to decide if the kids were treated fairly. They should have used the rule that says you have to use the best way to help people. The special way of helping is the best way, so the place where the kids were kept broke the rules.