In the Matter of the Personal Restraint of M.T.M.L., consolidated with In the Matter of the Personal Restraint of R.A.

Summary

In this consolidated published opinion, the Washington Court of Appeals, Division One, reviews personal restraint petitions challenging conditions at Green Hill School, a juvenile rehabilitation facility operated by the Department of Children, Youth, and Families. The court holds that the conditions described did not violate the Washington or United States Constitutions, but concludes that the facility violated Washington law and must remedy the conditions immediately. The opinion also addresses mootness, the continuing-and-substantial-public-interest exception, and an amicus motion.

Holdings

1. R.A.'s petition was moot because, after his transfer from Green Hill, the court could no longer provide effective relief, but the court retained review because the petition presented issues of continuing and substantial public interest likely to recur.
2. The conditions of petitioners' confinement did not violate article I, section 14 of the Washington Constitution or the Fourteenth Amendment's Due Process Clause.
3. DCYF violated Washington law by subjecting petitioners to room confinement beyond statutory limits and failing to provide required restroom and shower access; DCYF was required to remedy the conditions at Green Hill immediately.

Questions Presented

1. Whether R.A.'s personal restraint petition was moot and, if so, whether the court should review it under the continuing-and-substantial-public-interest exception.
2. Whether the conditions of petitioners' confinement violated article I, section 14 of the Washington Constitution's prohibition against cruel punishment.
3. Whether the conditions of petitioners' confinement violated the Fourteenth Amendment's Due Process Clause.
4. Whether the conditions at Green Hill violated Washington's statutory restrictions governing juvenile room confinement and required access to toilets, sinks, and showers.
5. Whether immediate release was an appropriate remedy for the violations.

Disposition

other