Court of Appeals Issues Victory to Civil Debtors Alleging Forced Labor and Wage Theft Claims Against Lackawanna County and Related Entities
Today, the United States Court of Appeals for the Third Circuit reinstated forced labor, wage theft, and racketeering claims brought by people who were civilly detained for child support debts and who allege they were compelled by Lackawanna County, Pennsylvania and a private corporation to work in grueling and dangerous conditions at the local recycling center in order to access court-ordered work release programs.
Plaintiffs William Burrell, Dampsey Stuckey, and Joshua Huzzard allege that a state court ordered them into civil detention in a prison operated by Lackawanna County, and directed that they be permitted to enter the work release program, through which they could have earned money to pay the debts that resulted in their incarceration. However, to access work release, Lackawanna County forced the Plaintiffs to work for several months in the county recycling center, which was operated by a private company, LRCI, owned by Dominick and Louis DeNaples. For their work sorting through garbage, sharp metal and glass, medical waste, and human feces, the Plaintiffs were paid only five dollars per day.
Today’s decision reverses an opinion by the federal district court dismissing Plaintiffs’ claims. In reinstating the claims, the Third Circuit held that Plaintiffs adequately alleged that the County, the Solid Waste Management Authority, and LRCI obtained their labor through prohibited means, including withholding basic necessities like food; physical restraint; and abuse of law and legal process, by “conditioning access to a work release program on the furnishing of a period of nearly free labor.” The court also held that Plaintiffs sufficiently alleged that they were entitled to minimum wage for their work, noting that their “off-site work, not done for the benefit of the jail but rather for the benefit of the public-private partnership between the Municipal Authority and the Recycling Center, is markedly different than inmates doing work within a facility ‘producing goods and services used by the prison.’”
Lead Plaintiff William Burrell, who originally filed the case pro se in 2014 and who secured a prior appellate victory before engaging legal counsel, said, “my fight for justice in this case started almost ten years ago. I’m so proud of this victory, and look forward to continuing to fight for the hundreds of people harmed by these practices who may have been too fearful to come forward on their own.”
Juno Turner, Litigation Director at Towards Justice, noted that “the Court’s affirmation that federal law reaches the abuses of power alleged by our courageous clients in this case is an important victory in the fight against forced work, which remains a persistent stain in our society. We’re grateful that the Court recognized the important issues presented by this appeal and look forward to gathering the evidence to support our clients’ claims in the discovery process.”
In addition to Towards Justice, the Plaintiffs are represented by Handley Farah & Anderson and the Community Justice Project, as well as the Georgetown Law Center’s Appellate Courts Immersion Clinic. The Plaintiffs are grateful for the support of the Civil Rights Division of the United States Department of Justice as well as the following organizations, all of which signed onto amicus briefs filed with the Third Circuit: Constitutional Accountability Center, ACLU of Pennsylvania, National Employment Law Project, Community Legal Services of Philadelphia, Justice at Work Pennsylvania, National Employment Lawyers Association, and the Pennsylvania Institutional Law Project.
Press Contact: Juno Turner, email@example.com, 303 589-3054