Background
In September of two thousand nineteen, twelve children in foster care filed a class action lawsuit in the Southern District of West Virginia against state officials, including the Governor and the Department of Human Services. The plaintiffs alleged widespread abuse, neglect, and systemic failures within the state’s foster care system that violated their Fourteenth Amendment substantive due process rights and various federal statutes. The district court dismissed the case in late February of two thousand twenty-five, ruling that federal courts lacked the power to provide the requested injunctive relief and that the plaintiffs failed to establish redressability under Article III standing requirements.
The court’s reasoning
The Fourth Circuit applied the two-step redressability test from Buscemi versus Bell, first determining whether the court has the power to grant the requested relief and second whether such relief would redress the injury. The court held that federal courts have a longstanding history and duty to remedy systemic constitutional violations through institutional reform decrees, citing precedents such as Brown versus Board of Education and Brown versus Plata. The court rejected the district court’s assertion that federal judges cannot administer state institutions, noting that equitable powers are broad and flexible when tailored to cure constitutional violations. The court found that the requested injunctive and declaratory relief would likely redress the plaintiffs’ injuries by improving safety, services, and oversight within the foster care system.
Because federal courts not only have the authority, but also a duty, to remedy systemic constitutional rights violations, we reverse.
Jonathan R. v. Morrisey, 25-1232 (4th Cir. 2025)
The dissent
What it means going forward
The decision restores the ability of federal courts to issue comprehensive injunctions requiring state agencies to reform foster care systems that violate constitutional rights, ensuring that systemic abuses can be addressed through judicial oversight rather than dismissed on standing grounds.