Kuren v. Luzerne County
Pennsylvania Supreme Court
146 A.3d 715 (2016)
The Luzerne County public defender's office (OPD) (plaintiff) sued Luzerne County (defendant) in an injunctive class action, alleging that severe underfunding and understaffing systemically prevented it from providing adequate assistance of counsel to indigent defendants, effectively amounting to a constructive denial of counsel at critical stages of criminal proceedings. The trial court dismissed for failure to state a cognizable cause of action, and the appellate court affirmed; the OPD appealed to the state supreme court, arguing its severely limited representation capacity constituted constructive denial of the right to counsel.
Whether courts allow class actions for injunctive relief if a public defender's office systemically fails to provide adequate assistance of counsel for indigent defendants at critical stages of criminal proceedings because of inadequate resources.