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Keywords

contractsettlementplaintiffdefendantmotion
contractplaintiffmotion

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Flores v. Sessions

Facts

On April 16, 2018, Plaintiffs filed a motion to enforce the Flores Settlement Agreement, claiming that ORR breached the agreement by implementing policies that included placing Class Members in Residential Treatment Centers (RTCs) and administering psychotropic drugs without proper consent. The Plaintiffs sought procedural remedies that were not explicitly provided in the Flores Agreement, such as notice and an opportunity to be heard before transfers to more restrictive facilities. The Defendants contended that they had not violated the agreement and that the TVPRA superseded certain aspects of the Flores Agreement.

Plaintiffs seek certain procedural remedies that are not set forth in the Flores Agreement, including an order requiring ORR to: provide notice and an opportunity to be heard by an immigration judge before a Class Member may be transferred to an RTC, staff-secure facility, or secure facility.

Issue

The main legal issues were whether the ORR's actions constituted a breach of the Flores Settlement Agreement and whether the TVPRA superseded the provisions of the Flores Agreement regarding placement and suitability of Class Members.

The court must first address the scope of its authority to enforce that Agreement and whether the TVPRA supersedes any of its provisions.

Rule

The court applied the legal principles governing the enforcement of consent decrees, treating them as contracts for enforcement purposes, and determined that the Plaintiffs were entitled to relief only as explicitly or implicitly authorized by the Flores Agreement.

Without question courts treat consent decrees as contracts for enforcement purposes.

Analysis

The court analyzed the Plaintiffs' claims regarding the alleged breaches of the Flores Agreement, focusing on the authority to enforce the agreement and whether the TVPRA superseded its provisions. The court found that the TVPRA did not conflict with the Flores Agreement and that the Plaintiffs could challenge the ORR's placement and suitability procedures through a motion to enforce. The court also noted that the procedural remedies sought by the Plaintiffs were not supported by the terms of the Flores Agreement.

The Court concludes that, on this motion to enforce, Plaintiffs are entitled to only such relief as is explicitly or implicitly authorized by the Flores Agreement.

Conclusion

The court granted in part and denied in part the Plaintiffs' motion to enforce the Flores Settlement Agreement, affirming that the TVPRA did not supersede the placement and suitability provisions of the agreement.

The Court GRANTS IN PART and DENIES IN PART Plaintiffs' motion to enforce.

Who won?

The court's decision was a partial victory for the Plaintiffs, as it recognized some of their claims regarding the enforcement of the Flores Agreement while denying others. The court upheld the authority to challenge ORR's actions under the agreement.

The Court concludes that the TVPRA did not supersede the placement and suitability provisions of the Flores Agreement because the two can be easily reconciled and Congress did not explicitly abrogate Class Members' rights under the Agreement.

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