Doe 1 v. State of Tennessee, The

CourtDistrict Court, M.D. Tennessee
DecidedSeptember 30, 2025
Docket3:24-cv-00777
StatusUnknown

This text of Doe 1 v. State of Tennessee, The (Doe 1 v. State of Tennessee, The) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe 1 v. State of Tennessee, The, (M.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

JOHN DOE 1, et al., ) ) Plaintiffs, ) ) v. ) No. 3:24-cv-00777 ) STATE OF TENNESSEE, et al., ) ) Defendants. )

MEMORANDUM OPINION

This putative class action challenges several policies and practices that allegedly harm the rights of disabled children in Tennessee’s juvenile justice system. Before the Court are two Motions to Dismiss (Doc. Nos. 59, 61) that have been fully briefed and are ripe for decision (see Doc. Nos. 60, 62, 65, 66, 67). For the following reasons, the motion brought by Lizzette Reynolds will be denied, and the motion brought by the other defendants will be granted in part and denied in part. I. FACTUAL ALLEGATIONS AND BACKGROUND The Court takes the following allegations from the 147-page, 860-paragraph First Amended Class Action Complaint (“Complaint”), accepts them as true, and draws all reasonable inferences in Plaintiffs’ favor. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). Due to the protracted nature of the Complaint, however, the Court will recite only those allegations necessary to resolve the pending motions. The named Plaintiffs in this case are four individuals and a representative organization known as Disability Rights Tennessee (“DRT”). The Complaint alleges that the individual Plaintiffs—John Doe 1, John Doe 2, John Doe 3, and Jane Doe 1—are children with one or more disabilities who are now, or are at imminent risk of being” detained in Tennessee’s juvenile justice system.1 (Doc. No. 53 ¶¶ 2 n.1; 37–62). The Complaint refers to these Plaintiffs and other similarly situated children with disabilities as “Youth.” (Id. ¶ 2 n.1). DRT is a “Protection and Advocacy Organization” designated by Congress “to protect and advocate for the rights of people

with disabilities” in Tennessee. (Id. ¶¶ 24–36). DRT brought this lawsuit in its “associational capacity” on behalf of the named plaintiffs and six of its constituents identified as S.W., J.T., O.V., R.A., C.K., and M.G. (Id. ¶ 20). The four Defendants in this case are the State of Tennessee, the Tennessee Department of Children’s Services (“DCS”), Margie Quin, and Lizzette Gonzalez Reynolds. The State of Tennessee “operates and oversees the administration of” DCS and the Tennessee Department of Education (“TDOE”), both of which are state agencies that receive federal funds. (Id. ¶¶ 67–68, 90). DCS “oversees Tennessee’s juvenile justice” system, (id. ¶ 68), and has the power to “[a]dminister, develop or oversee programs” and services “reasonably necessary for unruly [and] delinquent” children. Tenn. Code Ann. § 37-5-106(a)(1). TDOE “oversees public education in

Tennessee.” (Doc. No. 53 ¶¶ 68, 90). Quin is the Commissioner of DCS. (Id. ¶ 78). Reynolds is the Commissioner of Education and chief executive of TDOE. (Id. ¶ 88). The allegations in this case begin when Youth first enter the Tennessee juvenile justice system after being charged with committing a “delinquent or unruly act.” (Id. ¶¶ 2 n.1, 71, 106; see also Tenn. Code Ann. §§ 37-1-102(b)(10), (b)(33). Tennessee juvenile courts then hold proceedings to determine whether these children are guilty or innocent of the charges. See Tenn. Code Ann. § 37-1-103(a). Juvenile courts may detain Youth “prior to adjudication” if, among

1 The terms children or “child” refer to a “person under eighteen (18) years of age” or a “person under nineteen (19) years of age” under certain qualifying circumstances. Tenn. Code. Ann. § 37- 1-102 (b)(5). other things, there is “probable cause” to believe they committed the acts with which they are charged. (Doc. No. 53 ¶¶ 63, 107). Courts typically send these “Pre-Adjudication Youth” to Juvenile Detention Centers (“JDC”) “designated or operated by the court.” (Id. ¶ 108; Tenn. Code. Ann. § 37-1-116(a)(4)). DCS and Quin (“DCS Defendants”) “are responsible for oversight of

JDCs, which are either licensed by DCS Defendants or approved by them[.]” (Doc. No. 53 ¶¶ 71, 108, 125 (alleging that “Tennessee has seventeen JDCS”)). When a juvenile court adjudicates a Youth as “delinquent or unruly,” the court may commit the Youth to DCS custody for “post-adjudication services.” (Id. ¶¶ 70, 110). The DCS Defendants have sole “authority over placement decisions for young people committed to their custody; judges are not permitted to order that Post-Adjudication Youth be placed in a specific facility.” (Id. ¶¶ 111, 121). “The facilities where DCS Defendants confine Post-Adjudication Youth” include, but are not limited to: (i) Youth Development Centers (“YDCs”); (ii) Residential Child Care Agencies; (iii) other facilities licensed by the Tennessee Department of Mental Health and Substance Abuse Services; and (iv) out-of-state contracted facilities. (Id. ¶ 114). The Complaint collectively refers

to the facilities that hold Pre-Adjudication Youth (including JDCs) and Post-Adjudication Youth (including YDCs) as “DCS and DCS-licensed or approved facilities.” (Id. ¶¶ 69-72, 78, 184). Plaintiffs raise numerous allegations about the experiences of the individual Plaintiffs during the time they were detained in the Tennessee juvenile justice system. They also allege a laundry list of ways in which Defendants’ policies, practices, methods of administration, and procedures violate the rights of both Pre-Adjudication Youth and Post-Adjudication Youth. Plaintiffs contend, among other things, that “DCS and its agents (1) fail to assess and accommodate Youths’ disabilities; (2) fail to administer services, programs, and activities in the most integrated setting appropriate to the needs of Youth; (3) fail to provide Youth with medical and mental health treatment; (4) expose Youth to violence; (5) subject Youth to excessive force through the use of pepper spray; (6) place Youth in solitary confinement in circumstances that constitute cruel and unusual punishment and are not rationally related to any legitimate government objective or are excessive in relation to that purpose; and (7) deny Youth education.” (Id. ¶ 83; see also id. ¶¶ 195–

503). As a result, Plaintiffs asserts the following eleven causes of action against Defendants: • State of Tennessee: Failure to Accommodate, in violation of Title II of the Americans with Disabilities Act (“ADA”) (Count One) and Section 504 of the Rehabilitation Act (“Section 504”) (Count Three).

• DCS: Failure to Accommodate, in violation of the ADA (Count One) and Section 504 (Count Three); and Failure to Provide Community Integration, in violation of the ADA (Count Two) and Section 504 (Count Four).

• Quin (official capacity): Section 1983 claims based on violations of the Fourteenth Amendment for: Failure to Provide Medical and Mental Health Treatment (Count Five); State-Created Danger and Failure to Protect (Count Seven); Excessive Force (Count Eight); and Conditions of Confinement (Count Nine). In the alternative, § 1983 claims on behalf of Post-Adjudication Youth for Failure to Provide Medical and Mental Health Treatment (Count Six) and Cruel and Unusual Punishment (Count Ten), in violation of the Eighth Amendment.

• Quin and Reynolds (official capacities): Section 1983 claim based on Violation of Procedural Due Process under the Fourteenth Amendment (Count Eleven). (Id. ¶¶ 730–854).

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Doe 1 v. State of Tennessee, The, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doe-1-v-state-of-tennessee-the-tnmd-2025.