DOE 4 v. SHENANDOAH VALLEY JUVENILE CTR. COMM'N

Reversing the district court's grant of summary judgment to Defendant on Plaintiff unaccompanied immigrant children's claim that Defendant failed to provide adequate mental health care. The Court ruled that (1) Plaintiffs established standing although ORR was not named as a Defendant; (2) the proper standard is whether Defendant's actions departed from accepted professional judgment, not deliberate indifference; and (3) on remand, district court should consider evidence on trauma-informed care and the professional judgment standard. Judge Wilkinson dissented, concluding that the deliberate indifference standard should apply but that regardless of which standard applied, summary judgment was proper.

Date of Decision
Published