The motion alleges that K.B. has been confined in the adult jail since June 2025, beginning at age fourteen. The filing details specific incidents of violence and abuse, including a juvenile being body slammed by an adult inmate and another sustaining a head injury resulting in scarring.
Shaw’s counsel, Kenya Brooks, also alleges that K.B. was subjected to pepper spray and placed in solitary confinement for approximately thirty days on or about April 13, 2026. The motion argues that these conditions pose a substantial risk of serious harm under the Fourteenth Amendment.
Although the defendants began separating juveniles from adult inmates after the lawsuit was filed on March 31, 2026, the motion contends this separation was implemented through continued confinement in the adult jail rather than transfer to a juvenile facility.
The filing asserts that K.B. has faced continued isolation and adverse treatment following the initiation of the lawsuit, supporting an inference of retaliatory conditions. Shaw argues that government officials may not subject a detainee to adverse conditions in response to the exercise of constitutional rights.
The motion cites the Juvenile Justice and Delinquency Prevention Act as confirming that the risks of housing juveniles in adult jails are well known, even if the statute is not independently enforceable. It argues that isolation of a juvenile within an adult jail remains constitutionally deficient.
Shaw seeks a narrowly tailored order requiring K.B.’s immediate removal from the Ellisville facility, transfer to a juvenile facility, and protection from retaliatory treatment. The motion also requests reasonable attorney’s fees and costs pursuant to 42 U.S.C. § 1988(b).