A. v. Barnes

CourtDistrict Court, N.D. Georgia
DecidedAugust 27, 2025
Docket1:02-cv-01686
StatusUnknown

This text of A. v. Barnes (A. v. Barnes) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A. v. Barnes, (N.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION KENNY A., by his next friend Linda Winn, et al., Plaintiffs, v. CIVIL ACTION FILE NO. 1:02-CV-1686-TWT DEPARTMENT OF HUMAN RESOURCES OF THE STATE OF GEORGIA, et al., Defendants. OPINION AND ORDER This is an action to correct systemic issues in the foster care system of Fulton and DeKalb counties. It is before the Court on the Defendants’ Motion to Terminate the Consent Decree [Doc. 793], the Plaintiff’s Motion to Enforce the Consent Decree [Doc. 814], and the Defendants’ Motion for a Hearing [Doc. 817]. For the following reasons, the Defendants’ Motions to Terminate the Consent Decree [Doc. 793] and for a Hearing [Doc. 817] are DENIED, and the Plaintiff’s Motion to Enforce the Consent Decree [Doc. 814] is also DENIED. I. Background The facts of this case are familiar to the parties, and the Court provides only brief background information here. The Plaintiffs are a class of children in Fulton and DeKalb Counties (“Region 14”) who were removed from their family homes and placed into Defendants’ custody. In 2002, the Plaintiffs filed this action in state court seeking declaratory and prospective injunctive relief against the Defendants for statutory violations under state law and federal constitutional violations arising from the Defendants’ operation of the foster care system. The Defendants then removed the action to this Court. The

parties negotiated a consent decree to end the case, which the Court approved and entered in October 2005. The parties renegotiated the consent decree several times over the years, most recently in December 2016 (“2016 Consent Decree”). [Doc. 745-1]. The 2016 Consent Decree also includes an exit plan, which outlines a plan with specific obligations for the Defendants to meet in order to eventually terminate the consent decree. In early 2017, the parties

further agreed to add a set of “Infrastructure Standards” to the decree and exit plan. [Doc. 757]. The Infrastructure Standards are enforceable obligations intended “to measure the foundational elements of the child welfare system that provides care, treatment, placements, services, and protection of the Plaintiff Class.” (Infrastructure Standards, at 2); (2016 Consent Decree, at 20). The 2016 Consent Decree includes 31 Outcome Measures (“OMs”) for the Defendants to meet in furtherance of the parties’ shared goals, with their

performance measured at six and twelve-month intervals and classified as either “attained” or “ongoing.” (2016 Consent Decree at 4-5, 9-15, 19). An OM is considered “attained” if, in the previous three consecutive reporting periods, the Defendants improved their performance in the first period and then met or exceeded the measure in the next two periods. ( at 19). The Defendants are

2 permitted to seek an order terminating the consent decree “[o]nce all of the outcome measures are designated as [a]ttained [o]utcome [m]easures, and there are no remaining [o]ngoing [o]utcome [m]easures.” ( at 20). Since the

2016 Consent Decree and Infrastructure Standards were entered, the parties have routinely submitted their monitoring reports and briefs on infrastructure standards. In September 2024, the Defendants filed their Motion to Terminate the Consent Decree [Doc. 793]. The Plaintiffs opposed the Motion and separately filed a Motion to Enforce the Consent Decree. [Doc. 814]. In June 2025, the

Defendants notified the Court that a mediation on this matter had failed and moved for a status conference. [Doc. 817]. These Motions are presently before the Court. II. Discussion A. Defendants’ Motion to Terminate [Doc. 793] In moving to terminate, the Defendants argue that there have been significant factual and legal changes and “new policy insights” since the

original consent decree was entered in 2005 that make continued enforcement inequitable. (Defs.’ Mot. to Terminate, at 10-33). Specifically, the Defendants point to the introduction of Georgia’s new juvenile code in 2013, structural and operational changes at DFCS implemented in 2009, 2014, and 2015, the introduction of the State of Hope initiative in 2018, the addition of the Office

3 of Health Law and Policy in 2022, and increased funding for DFCS workers. ( at 10-23). They also contend that the federal government has “dramatically increased” its oversight of child welfare systems since 2005. ( at 23-27).

Additionally, the Defendants argue that no ongoing violations of federal law support continued enforcement of the decree, and that continued enforcement is against the public interest. ( at 33-58). In response, the Plaintiffs argue that the Defendants are not in compliance with at least six OMs, negating their contention that they have substantially complied with the decree’s terms. (Pls.’ Opp. to Mot. to

Terminate, at 23-25). Further, the Plaintiffs contend that none of the factual or legal changes relied upon by the Defendants were both significant and unforeseen. ( at 25-30). Regardless, they assert, the Defendants have not shown the implementation of a durable remedy to the Plaintiffs’ allegations such that prospective relief is no longer warranted. ( at 31-54). On motion and just terms, the Court can relieve a party from its order when the judgment has been satisfied, applying the order prospectively is no

longer equitable, or for any other reason that justifies relief. Fed. R. Civ. P. 60(b)(5), (6). The party seeking termination “bears a heavy burden of persuasion” to justify termination. , 977 F.3d 1061, 1073 (11th Cir. 2020) (citation omitted). In an institutional reform case where the movant argues that enforcement of the consent decree is no longer equitable,

4 “a party seeking modification of a consent decree bears the burden of establishing that a significant change in circumstances warrants revision of the decree.” , 502 U.S. 367, 383 (1992).

Modification or termination may be warranted when the factual conditions have changed such that “compliance with the decree [is] substantially more onerous;” when the “decree proves to be unworkable because of unforeseen obstacles; or continued enforcement of the decree would be “detrimental to the public interest.” at 384. However, a party may not seek modification of a consent decree on the grounds that “it is no longer convenient to live with the

terms of a consent decree.” at 383. And to that end, “modification should not be granted where a party relies upon events that actually were anticipated at the time it entered into a decree.” at 385 (“If it is clear that a party anticipated changing conditions that would make performance of the decree more onerous but nevertheless agreed to the decree, that party would have to satisfy a heavy burden to convince a court that it agreed to the decree in good faith, made a reasonable effort to comply with the decree, and should be

relieved of the undertaking under Rule 60(b).”). Only once the Court has determined that changed circumstances warrant a modification does the Court consider whether the proposed modification, in this case termination, is the appropriate remedy to the problems posed by the change in circumstances. at 391. And once these two factors are met, the court must still ensure that

5 “the objects of the decree have been attained” before it may terminate it. , 540 U.S. 431, 442 (2004). Additionally, a movant can show that a judgment has been satisfied

under Rule 60(b)(5) if it is in “substantial compliance” with the consent decree.

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A. v. Barnes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/a-v-barnes-gand-2025.