Washington Appellate Court Uses Personal Restraint Petitions Mooted by Prisoners’ Transfers to Order Remedial Measures at Troubled Juvenile Lockup
by Chuck Sharman
On December 1, 2025, the Washington Court of Appeals found that conditions at the state’s toughest juvenile prison violated state law. The case was remarkable for using a habeas corpus action—known in Washington as a personal restraint petition (PRP)—to challenge a prisoner’s conditions of confinement. The Court’s ruling was equally remarkable in agreeing to do so, even after transfer of plaintiffs “M.T.M.L.” and Royal Jordan E. Adams to other lockups mooted their pleas for release.
Both were confined at Green Hill School, Washington’s only maximum-security juvenile prison, though some prisoners remain there up to age 25. A grim history of sexual violence was laid out in suits filed by 10 former detainees that the state Department of Children, Youth and Families (DCYF) settled in 2021 for a total of $2.135 million, as PLN reported. [See: PLN, Oct. 10, 2022, online.]
After that payout, a drug crisis erupted, including a fentanyl overdose suffered by one “resident,” as prisoners are known. During the ensuing investigation, a Joint Narcotics Enforcement Team made up of state and local law enforcement personnel recovered 1,000 illegal pills. Nine sets of related charges were filed by the end of 2023, along with additional charges stemming from a dozen riots that broke out as the prison’s population exploded from 160 to 240 between January 2023 and June 2024.
It was against this chaotic backdrop that Plaintiffs filed their PRPs. In the petitions, they alleged that chronic understaffing kept them confined to their cells during extended lockdowns that followed the frequent outbreaks of violence. Worse, the cells were “dry”—lacking any plumbing—forcing the residents to endure long waits for an available guard to provide an escort to a restroom. Worse still, residents were not permitted to use the restroom except alone, extending the wait so long that the DCYF provided them “medical grade urine bottles,” as the Court later recalled.
The repeated and prolonged lockdowns disrupted programming, of course; M.T.M.L. claimed that he was provided just one mental health counseling session during a 10-week stretch. Beyond restroom access, prisoners were also deprived of access to showers, they said. The two Plaintiffs filed their PRPs in 2024, and the Court consolidated both and granted review.
In its ruling, the Court agreed that the Plaintiffs’ transfers out of Green Hill foreclosed any relief to them. The Court also agreed that having found the claim moot, it generally declines review—except when presented with “an issue of continuing and substantial public interest.” As provided by In re Marriage of Horner, 151 Wn.2d 884 (2004), that asks “(1) whether the issue is of a public or private nature; (2) whether an authoritative determination is desirable to provide future guidance to public officers; and (3) whether the issue is likely to recur.”
Answering all three questions affirmatively, the Court moved on to the first allegation, that the conditions of confinement violate the state and federal constitutions. The Court allowed that conditions “raise serious concerns about the treatment of juveniles in custody” but “do not rise to the level of a constitutional violation.” Neither prisoner was disabled, and neither soiled himself while waiting for a restroom escort or using one of the urine bottles, so the Court was unwilling to find that DCYF “deprive[d] them of the basic necessitates of human dignity.”
Even were that so, DCYF claimed, the lockdowns were to blame and there was a “legitimate penological interest” for those—securing the agency’s facilities—as required by Bell v. Wolfish, 441 U.S. 520 (1979). The Court didn’t need to make a finding here, but it warned that “DCYF cannot implement policies limiting the resident’s access to programming and claim it is because of safety and security concerns when it is DCYF’s own inability to resolve the issues of overpopulation and understaffing that gave rise to those concerns.”
Turning to state law, the Court noted the definition of “room confinement” in RCW 13.22.010 and found it described what Plaintiffs endured during lockdowns. But room confinement is limited by statute to no more than four hours in any 24-hour period, and for its duration “the juvenile must be checked on at least every fifteen minutes, have access to a toilet and sink at least hourly, and have access to a bath or shower daily.” Since DCYF admitted that it fell short of these requirements, the Court found it in violation of state law and ordered the agency to cure the defects.
Before the Court, Plaintiffs were represented by attorneys Katherine E. Hurley and Kate Benward from King County Public Defense. The American Civil Liberties Union of Washington, Columbia Legal Services and TeamChild also filed amicus curiae briefs. See: In re Pers. Restraint of M.T.M.L., 35 Wn. App. 2d 868 (2025).
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