from the United States District Court for the Southern
District of Mississippi
REAVLEY, ELROD, and HIGGINSON, Circuit Judges.
JENNIFER WALKER ELROD, CIRCUIT JUDGE.
case presents a question of statutory interpretation. The
question is whether the phrase "officials or employees
of any governmental agency with responsibility for the
administration of juvenile justice," as it is used in 34
U.S.C. § 12601(a), includes the judges of a county youth
court. Holding that it does not, we AFFIRM the judgment of
the district court.
is a question of statutory interpretation, we begin with the
text of the statute. In 1994, Congress passed the Violent
Crime Control and Law Enforcement Act. Relevant to this
case are the provisions found in Title XXI, § 210401,
108 Stat. 2071, now codified at 34 U.S.C. § 12601. That
section, enacted under a title heading of "State and
Local Law Enforcement," and a subtitle heading of
"Police Pattern or Practice," reads as follows:
(a) Unlawful conduct
It shall be unlawful for any governmental authority, or any
agent thereof, or any person acting on behalf of a
governmental authority, to engage in a pattern or practice of
conduct by law enforcement officers or by officials or
employees of any governmental agency with responsibility for
the administration of juvenile justice or the incarceration
of juveniles that deprives persons of rights, privileges, or
immunities secured or protected by the Constitution or laws
of the United States.
(b) Civil action by Attorney General
Whenever the Attorney General has reasonable cause to believe
that a violation of paragraph (1) has occurred, the Attorney
General, for or in the name of the United States, may in a
civil action obtain appropriate equitable and declaratory
relief to eliminate the pattern or practice.
34 U.S.C. § 12601.
United States Department of Justice initiated this litigation
in October 2012. In its complaint, the United States alleged,
inter alia,  that Lauderdale County and its two Youth
Court judges operated a "school-to-prison
pipeline" and, through their administration of the
juvenile justice process, were engaged in patterns or
practices that denied juveniles their constitutional rights
under the Fourth, Fifth, and Fourteenth Amendments.
we further address the litigation underlying this appeal, it
will be useful to offer some background on the Lauderdale
County Youth Court, its judges, and its procedures. In
Mississippi, county youth courts are divisions of the county
courts, and the judges of the county courts are also the
judges of the youth courts. Miss. Code Ann. § 43-21-107.
County judges are elected for terms of four years, and the
Governor has authority to fill vacancies by appointment.
Id. §§ 9-9-5, 9-7-1, 9-1-103. Lauderdale
County is authorized two county judges. Id. §
9-9-18.3. When a juvenile is charged with offenses under
youth court jurisdiction, he or she is brought before an
intake officer of the court who establishes jurisdiction and
recommends whether informal resolution or custody is
warranted. Id. § 43-21-357. If the juvenile is
placed into custody, he or she must be brought before a youth
court judge within 48 hours-excluding weekends and
holidays-for a probable cause determination. Id.
§ 43-21-301. If needed, the juvenile is appointed a
guardian ad litem and/or defense counsel.
Id. §§ 43-21-121, 43-21-201. If the
juvenile is held in custody, an adjudicatory hearing must be
held within 21 days, with a few exceptions. Id.
§ 43-21-551. If the juvenile is adjudicated to be
delinquent or in need of supervision, a disposition hearing
must then be scheduled within 14 days. Id. §
43-21-601. If the disposition requires detention, the
detention cannot exceed 90 days. Id. §
43-21-605(1)(1). To perform the work of the youth courts, the
youth court judges may appoint intake officers, guardians
ad litem, defense counsel, and prosecutors.
Id. §§ 43-21-119 (intake officers);
43-21-117 (prosecutors); 43-21-121 (guardians ad
litem); 43-21-201 (defense counsel). The county board of
supervisors controls the funding and budget for county youth
courts. Id. § 43-21-123.
government brought this action against Lauderdale County and
its Youth Court judges under 34 U.S.C. § 12601 (formerly
codified at 42 U.S.C. 14141). By way of alleged
constitutional violations, the government alleges that the
Lauderdale County judges: delay detention hearings for longer
than 48 hours; do not base their detention determinations on
whether probable cause exists; do not consistently provide
defense counsel; do not clearly articulate the standards for
school suspensions; do not conduct hearings that determine