Hoffman v. Knoebel
| Decision Date | 27 July 2017 |
| Docket Number | No. 4:14-cv-00012-SEB-TAB,4:14-cv-00012-SEB-TAB |
| Parties | DESTINY HOFFMAN On behalf of themselves and on behalf of others similarly situated, et al. Plaintiffs, v. SUSAN KNOEBEL, et al. Defendants. |
| Court | U.S. District Court — Southern District of Indiana |
ORDER GRANTING DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT
This cause is before the Court on motions for summary judgment filed by four Defendants: Susan Knoebel [Docket No. 225], Jeremy Snelling [Docket No. 225], Josh Seybold [Docket No. 230], and Clark County Sheriff Danny Rodden [Docket No. 224]. For the reasons detailed below, we GRANT these motions, ruling in all respects in Defendants' favor.
Background
This case calls into question the legality of various practices of the Clark County Drug Treatment Court ("DTC") vis-à-vis various participants in the DTC's Program from 2011 to 2013.
Establishment and Certification of the DTC
The DTC was established by the Clark Superior Court in 2002 when it was certified as a "problem solving court" by the Indiana Judicial Center. As a drug-related problem-solving court, the DTC was designed to "focus[] on addressing the substance abuse issues of defendants or juveniles in the criminal justice system by: (1) bringing together substance abuse rehabilitation professionals, local social programs, and intensive judicial monitoring; and (2) linking eligible defendants or juveniles to individually tailored programs or services." Ind. Code at § 33-23-16-5.
Once certified, the DTC operated out of Clark Superior Court 2 from 2002 until 2012, at which time the Clark County courts were unified resulting in Superior Court 2 becoming Circuit Court 2. Judge Jerome Jacobi, who had been elected to Superior Court 2 in 2008, became the presiding judge of Clark Circuit Court 2 and also became "Supervising Judge" for the DTC, which vested in him "ultimate responsibility" for the problem-solving court. See Ind. Prob. Solving Ct. Rule 3, found at https://www.in.gov/judiciary/pscourts/files/pscourts-psc-rules.pdf (last visited July 12, 2017).
As Supervising Judge, Judge Jacobi was authorized by statute to Id. at § 33-23-16-21.
Judge Jacobi hired Defendant Susan Knoebel to serve as his chief probation officer in Circuit Court 2 and Director of the DTC Program. He also hired Defendant Jeremy Snelling to serve as his bailiff for Clark Circuit Court 2 and a "field officer" for the DTC. Neither "director" nor "field officer" is a defined position under the Indiana Problem Solving Court Rules as promulgated by the Indiana Judicial Center. But, according to Knoebel, as director of the DTC, she was charged with administrative oversight of the program, which entailed supervising the DTC case managers. Knoebel Decl. ¶ 3.1 She did not, however, have hiring or firing authority nor could she unilaterally promulgate policies or procedures for the DTC, as those powers remained with Judge Jacobi as the supervising judge of the court. Id. Jeremy Snelling reports that when Judge Jacobi hired him as his bailiff, he was told that he had the authority to make arrests within the courthouse and that, in addition to his typical bailiff duties, he would be a member of the DTC Treatment Team as a field officer, which role entailed, among other things, conducting home inspections and curfew compliance checks and "escorting"DTC participants who were subject to arrest warrants to the Clark County Jail. Snelling Decl. ¶¶ 4, 5, 8.
Defendant Josh Seybold and Jessie McDowell, who was later replaced by Iris Rubadue (neither McDowell nor Rubadue has been named as a Defendant in this action), were hired as case managers for the DTC participants. The Indiana Problem-Solving Court Rules define a case manager as "a problem-solving court team member responsible for the case management of problem-solving court participants and case management files, which may include administering a risk and needs assessment, substance abuse and mental health screening, referral to treatment and ancillary services; monitoring participant compliance with the participation agreement, case management plan and other applicable agreements; and providing participant progress and compliance information to the problem-solving court team." Ind. Prob. Solv. Ct. Rule 3. The remainder of the DTC Staffing Committee included Magistrate William Dawkins, a representative of the prosecutor's office, a representative of the public defender's office, mental health and substance abuse service providers, halfway house directors, and law enforcement representatives.
Operations of the DTC
The DTC was structured to provide certain criminal defendants in Clark Circuit Court 2 who had pled guilty to drug-related felonies the opportunity to opt into the DTC Program as an alternative to incarceration. In such circumstances, the defendant would execute a Drug Court Agreement approved by Judge Jacobi and the Indiana JudicialCenter, which explained that in exchange for agreeing to enter the DTC Program the Clark Circuit Court would defer entering a judgment of conviction against him/her and instead would impose on the participant certain conditions and limitations established for the DTC Program. Knoebel Decl. ¶ 7, Ex. A. If a participant successfully completed the DTC Program, the State would dismiss with prejudice the criminal charges to which he/she had pled guilty. Id. If, however, the court determined that the person had violated the conditions of the DTC, as prescribed in the Drug Court Agreement and the DTC Participant Handbook, participation in the DTC Program would be terminated (following a "due process hearing on Petition to Terminate"), a judgment of conviction would be entered, and a sentenced would be imposed pursuant to the plea agreement based on the offenses of conviction. Id. Typically, following the execution of these plea and drug court agreements, the defendants' attorneys would withdraw their representation from the cases.
Upon entry into the DTC Program, each participant was assigned to one of the two DTC case managers, who prepared an individualized treatment plan designed to aid in his or her substance abuse recovery. These plans typically required, inter alia, that a participant obtain treatment from a DTC-approved provider, attend self-help meetings, and maintain employment. The DTC also approved the participant's living arrangement, which, depending on the particular participant's circumstances, would be a private residence, a treatment facility, or a group home such as a halfway house. While participating in the DTC Program, participants also were subject to various conditionsand restrictions comparable to those imposed on probationers, such as unannounced home visits and random drug screens, in addition to heightened levels of judicial oversight.
As part of such judicial oversight, the DTC Staffing Committee, usually consisting of the presiding judge (either Judge Jacobi or Magistrate Judge Dawkins or both), DTC Director Knoebel, the DTC case managers, an administrative assistant, a deputy prosecutor, and a defense attorney, held weekly meetings each Thursday at noon to discuss the participants' progress and behavior.2 During these weekly meetings, case managers presented for discussion reports on the progress of each participant who was scheduled to appear at a status hearing that same afternoon. Discussions often covered issues related to possible sanctions for noncompliant behavior such as testing positive or diluting a urine screen, failing to report or attend a group meeting, failing to gain or keep employment, being arrested, or failing to comply with other conditions imposed by the participant's individualized treatment plan. Knoebel Decl. ¶ 10. Tentative decisions regarding the appropriate sanctions or behavior modifications for particular rules infractions were generally reached by consensus; however, certain committee members, including Case Managers Josh Seybold and Iris Rubadue and Director Susan Knoebel, sometimes recommended sanctions, leaving the final decision to the judge presiding atthe status hearing later that day. Id. ¶ 11.3 Sanctions typically included demoting a participant to a lower phase in the Program, requiring community service, assigning the writing of a reflective essay, increasing the frequency of status hearings, imposing "short-term jail stays," or terminations from the Program. Id. ¶ 9.
Following the Staffing Committee meetings, the DTC conducted the status hearings with the participants. The presiding judge, Director Susan Knoebel, Bailiff Jeremy Snelling, the DTC participants, and various Clark County Jail officers also attended these hearings; however, neither the Staffing Committee attorneys nor any other attorneys were present during the DTC proceedings. During the hearings, the presiding judge heard from the participants, discussed their progress and alleged infractions, and, when necessary, issued sanctions, which could include ordering the remand of certain participants to the custody of the Clark County Sheriff to be detained in the Clark County Jail. See Dkt. 231 at 13.
In certain instances, if a participant failed a drug test, the presiding judge imposed a sanction on the participant that involved a "short-term jail stay," in which, as the judge explained to the participant, the detention was for a specific, limited period of time, typically 48 or 72 hours. In other instances, typically involving second or third infractions, the judge ordered a longer period of detention—i.e., up to 30 days in jail. On other occasions, the judge imposed a 48-hour or 72-hour sanction, which generated aBond Notice to Sheriff...
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