Morales v. Turman

Background

A group of juveniles confined in Texas institutions, represented by their lawyers, sued the Texas Youth Council. They alleged punitive and inhumane conditions and a failure to provide the rehabilitation or treatment that justified confinement. A single federal District Judge found constitutional violations and ordered the parties to submit a curative plan. The Court of Appeals vacated that decision, holding that a three-judge court should have been convened because the challenged practices were shown at trial to have statewide effect.

Reasoning

The main question was whether challenges to generalized, unwritten administrative practices must be heard by a three-judge court under 28 U.S.C. § 2281. The Court explained that the special three-judge procedure applies when a party seeks to restrain enforcement of a state statute or a formal rule issued by an administrative board. The opinion rejected treating informal, unwritten practices as equivalent to delegated legislation, relying on prior decisions that required an identified rule or regulation. The Court concluded the single district judge properly exercised jurisdiction and allowed the case to proceed on the merits, reversing the Court of Appeals.

Real world impact

The decision lets federal judges reach the substance of constitutional claims about conditions in juvenile facilities without automatically convening a three-judge panel when only informal statewide practices are alleged. That reduces procedural uncertainty and potential delay for juveniles seeking relief. The opinion also notes the statute governing three-judge courts was prospectively repealed but still applied to cases pending at the time; the Supreme Court reversed and remanded for further proceedings.