This Article discusses the case Doe 4 ex rel. Lopez v. Shenandoah Valley Juvenile Center Commission. This case was a class action brought by unaccompanied immigrant children against the Shenandoah Valley Juvenile Center Commission under § 1983 protection for adequate medical care. The plaintiff class alleged that, among other things, the Commission failed to (i) provide adequate mental health care due to punitive practices; and (ii) implement trauma-informed care. The plaintiffs were immigrant children who fled their native countries due to harrowing circumstances, many of whom struggled with severe mental illness. The district court granted the defendant’s motion for summary judgment regarding the mental health care claim, which the plaintiffs appealed. On appeal, the Fourth Circuit considered which standard should be applied to analyzing a claim regarding the detention center’s level of mental health care. This Article explores the approach and impact of Doe 4, as a case of first impression for the Fourth Circuit and effectively for all circuits with regard to this class of immigrant children. Specifically, this Article discusses whether the majority opinion followed precedent or broke away from it in a way that properly embodies federal law and Constitutional guarantees. This Article also discusses the role of international law in United States courts, particularly related to protections for migrants and children. The Article ultimately concludes that the Fourth Circuit’s decision in Doe 4 was correct and explains why and how it should be further adopted and adapted by other federal courts, to promote an end to the professional indifference that the United States judicial system has normalized with regard to care for juveniles in detention centers.
Caitlin Fernandez Zamora,
Professional Indifference?: How One Case Improves Protection for Immigrant Children in United States Detention Centers,
Nw. J. Hum. Rts.