SOUTH CAROLINA STATE CONFERENCE OF THE NAACP; DISABILITY RIGHTS SOUTH CAROLINA; JUSTICE 360 Plaintiffs – v. SOUTH CAROLINA DEPARTMENT OF JUVENILE JUSTICE; EDEN HENDRICK
The Fourth Circuit affirmed the dismissal of an institutional reform lawsuit against South Carolina's Department of Juvenile Justice because the plaintiff advocacy groups lacked Article III standing. The court held that organizations cannot substitute for detained juveniles to drive litigation regarding conditions of confinement.