Latest 2 Cases: Doe v. Shenandoah Valley Juvenile Center Commission (Civil Rights), United States v. Singletary (Criminal Law)

The Invisible Man and His Visible Victim

SHERRY F. COLB

Cornell law professor Sherry F. Colb comments on a movie some have described as one of the best of 2020, The Invisible Man, and describes how the story in the movie offers possibilities for envisioning accountability for domestic violence and other crimes that often receive dismissive treatment under the heading of “he said/she said.” Professor Colb briefly describes the plot of the movie (including spoilers), and explains why the movie is so revelatory.

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Doe v. Shenandoah Valley Juvenile Center Commission

Docket: 19-1910

Opinion Date: January 12, 2021

Judge: Roger L. Gregory

Areas of Law: Civil Rights, Class Action, Constitutional Law, Juvenile Law

A facility caring for an unaccompanied child fails to provide a constitutionally adequate level of mental health care if it substantially departs from accepted professional standards. Appellants, a class of unaccompanied immigrant children detained at Shenandoah Valley Juvenile Center (SVJC), filed a class action alleging that the Commission fails to provide a constitutionally adequate level of mental health care due to its punitive practices and failure to implement trauma-informed care. The district court found that the Commission provides adequate care by offering access to counseling and medication. The Fourth Circuit held that neither the Flores Settlement nor SVJC's cooperative agreement prevent appellants from addressing their alleged injuries through the relief they seek from SVJC. On the merits, the court applied the Youngberg standard for professional judgment and reversed the district court's grant of summary judgment in favor of the Commission. The court explained that the district court incorrectly applied a standard of deliberate indifference when it should have determined whether the Commission substantially departed from accepted standards of professional judgment. Therefore, in light of the Youngberg standard, the district court must consider evidence relevant to the professional standards of care necessary to treat appellants' serious mental health needs. The court left it to the district court to determine in the first instance to what extent, if any, the trauma-informed approach should be incorporated into the professional judgment standard in this particular case. Accordingly, the court remanded for further proceedings.

United States v. Singletary

Docket: 19-4381

Opinion Date: January 12, 2021

Judge: Pamela Harris

Areas of Law: Criminal Law

The Fourth Circuit vacated defendant's 13-year sentence and 5-year term of supervised release imposed after he pleaded guilty to Hobbs Act robbery and to use of a firearm in the course of a crime of violence. The court held that two financial conditions of supervised release that appeared in defendant's written judgment were not pronounced orally by the district court during his sentencing hearing. Therefore, under the court's recent decision in United States v. Rogers, 961 F.3d 291 (4th Cir. 2020), defendant was never sentenced to those conditions. Accordingly, the court vacated the sentence and remanded for resentencing.