K.Y. v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedJanuary 16, 2026
DocketCivil Action No. 2024-3056
StatusPublished

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

Bluebook
K.Y. v. District of Columbia, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

K.Y., et al.,

Plaintiffs,

v. Civil Action No. 1:24-cv-03056 (CJN)

DISTRICT OF COLUMBIA, et al.,

Defendants.

MEMORANDUM OPINION

K.Y. and D.J., two minors who were committed to the custody of the D.C. Department of

Youth Rehabilitation Services after being adjudicated delinquent, challenge their extended

detention in a secure facility called the Youth Services Center while awaiting a rehabilitation

placement. ECF 1. At issue here, K.Y. and D.J. move to certify a class of all “[y]outh who are

currently or will be (1) committed to the custody of the D.C. Department of Youth Rehabilitation

Services; (2) detained at the Youth Services Center; and (3) awaiting placement.” ECF 2 at 1. For

the reasons that follow, the Court denies their motion.

I. Background

Starting in the late summer of 2024, K.Y. and D.J. spent several months in the Youth

Services Center while the D.C. Department of Youth Rehabilitation Services worked to match

them with a long-term rehabilitation provider. See ECF 1 at 4. According to K.Y. and D.J., the

Department’s placement process has broken down, leaving many other children like them similarly

languishing at the Center for months. Id. at 3. They contend that extended stays at the Center are

contrary to the Department’s rehabilitative goals given that this “jail-like facility . . . is crowded,

violent, and harmful to children at a critical time in their development.” Id.

1 In late 2024, K.Y. and D.J. sued the District of Columbia and Sam Abed, the Director of

the Department. Id. at 1. They argue that their extended detention at the Center violated the Fifth

Amendment’s Due Process Clause and several provisions of District law, and they also bring

claims premised on theories of negligence and negligence per se. Id. at 22–33. K.Y. and D.J.

concurrently moved to certify a class made up of all those who are currently held or will be held

at the Center while awaiting placement. ECF 2 at 1. And a few days after filing that motion, they

moved for a preliminary injunction that would require the District to place all children committed

to Department custody in a timely manner. ECF 7 at 1.

The Court held a hearing on the motion for a preliminary injunction in December 2024.

See Min. Entry of Dec. 12, 2024. Within a few days of that hearing, the Department successfully

placed K.Y. and D.J. at rehabilitative facilities. See ECF 25 at 1. K.Y. and D.J. accordingly

requested that the Court hold their motion for a preliminary injunction in abeyance pending

briefing on whether to certify a class. Id. at 1–2. The Court granted that request. See Min. Order

of Dec. 17, 2024.

During the same time frame, the D.C. Council took action to address some of K.Y. and

D.J.’s concerns. When this suit began, D.C. law required the Department to “complete an initial

assessment of the child within 3 days of taking legal custody of the child and receipt of the social

file from the Director of Court Social Services” and “develop the individualized treatment plan

within 14 days of completing the initial assessment of the child, unless a longer diagnostic phase

is needed for the child and is justified in writing in the child’s initial assessment.” Omnibus

Juvenile Justice Act of 2004, § 902, 2004 D.C. Laws 15-261 (codified as amended at D.C. Code

§ 16-2319(f)). In December 2024, however, the D.C. Council passed the Recidivism Reduction

at DYRS Amendment Act of 2024 (ROAD Act), which amended some of these rules. See ECF

2 28 at 3. Under the ROAD Act, the Department now shall, “[w]ithin 10 days” “[f]ollowing Court

Social Services’s or the Office of the Attorney General’s notice to the Division of its

recommendation to commit a child to the Department,” “perform a validated risk and needs

assessment” of that child. D.C. Code § 16-2319(d). The Act also directs the Department to

“[c]onvene a predisposition meeting to review the validated risk and needs assessment and any

information on the child that the Department deems necessary, including evaluations, to begin the

development of an individualized rehabilitation plan for the child” that is completed “[n]o later

than 2 days . . . before the dispositional hearing.” Id.

Through a series of subsequent filings, the Parties contested the ROAD Act’s relevance to

this case and its effect on the speed of placements. K.Y. and D.J. argue that the Act’s “changes to

statutory deadlines for initial assessments and individualized treatment plans do not address [the

Department]’s systemic failures in securing placements.” ECF 34 at 1–2. Moreover, although

K.Y. and D.J. concede that the Act became effective in March 2025, they contend that it “has not

and cannot be implemented unless and until the underlying costs are funded through the District’s

appropriations process.” Id. The Act states that the relevant portions “shall apply upon the date

of inclusion of their fiscal effect in an approved budget and financial plan,” Recidivism Reduction

at DYRS Amendment Act of 2024, § 7(a), 2024 D.C. Laws 25-321, but it is not clear that sufficient

appropriations have been made yet, see ECF 34 at 2; ECF 35-1 at 4. The District responds that

the ROAD Act’s enactment counsels against “judicial intervention” given that it shows that

“policymakers in the executive and legislative branches of District government” are working to

address K.Y. and D.J.’s concerns. ECF 33 at 2. And it argues that the changes made by the ROAD

Act show that K.Y. and D.J. “misstated the requirements of District law.” Id.

3 In the interim, even with enactment of the ROAD Act (albeit potentially without complete

funding), the issue of lengthy pre-placement commitments at the Center has persisted. The number

of minors held at the Center awaiting placement has remained relatively constant, if not trended

up slightly, since the beginning of this litigation. The relevant population dropped in the spring of

2025 and rose a little bit in the late fall of 2025, but it has remained between 20 and 30 minors

during most months this litigation has been pending. Similarly, the average time spent at the

Center by such minors has remained relatively stable since peaking in late July 2025, with the

average length of stay largely oscillating between 75 and 100 days. The charts below illustrate

these changes (and lack thereof) over time.

4 Office of Independent Juvenile Justice Facilities Oversight, DYRS Secure Facilities Population

Data Over Time, https://oijjfo.dc.gov/page/dyrs-secure-facilities-population-data-over-time (last

visited Jan. 16, 2026); see also ECF 35-1 at 2 & n.5; ECF 37 at 2–3.

II. Analysis

“The class action is ‘an exception to the usual rule that litigation is conducted by and on

behalf of the individual named parties only.’” Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 348

(2011) (quoting Califano v. Yamasaki, 442 U.S. 682, 700–701 (1979)). Federal Rule of Civil

Procedure 23(a) limits the availability of class actions by dictating four prerequisites for class

certification. See Fed. R. Civ. P. 23(a).

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