Gary H. v. Hegstrom challenged the conditions of confinement and adequacy of treatment programs for juveniles at the MacLaren School for Boys, the maximum security institution for delinquents in Oregon. In December, 1984, U.S. District Court Judge James Burns ruled that isolation practices at MacLaren were unconstitutional. He found that an excessive number of juveniles were placed in isolation for unnecessarily long periods. The judge also found that inmates in the isolation units at MacLaren suffered from unsanitary living conditions, inadequate heat and ventilation, punitive disciplinary measures, poor diet and an absence of educational and recreational programming. In November, 1987, the Ninth Circuit Court of Appeals upheld all of Judge Burns’ factual findings and legal conclusions.