Via immigration lawyer Bryan Johnson:

“Mr. Kelly continues to knowingly detain child #1; child #2; and child # 3 in clear violation of 55 PA Code § 3800.283(7); 237 Pa. Code. 200.1(a); which, taken together, expressly prohibit placing non-delinquent children, non-dependent, or children under the age of 10 in a secure facility.

In doing so, Mr. Kelly has caused each child severe and potentially fatal harm, including but not limited to causing children to suffer from 309.81 Post traumatic Stress Disorder, Delayed Onset, Chronic.; 309.81 Post traumatic Stress Disorder, Chronic; 309.28 [F43.23] Adjustment Disorder with Mixed Anxiety and Depressed Mood; Suicidal Ideation; and Suicidal Gestures.

Mr. Kelly has and continues, through his agents in DHS and contracted staff at BCRC, to intentionally and unlawfully deprive children of sleep by flashing bright lights
on their faces at 15 minute intervals from 8:30 pm to 6:30 am, a total of 40 interruptions in sleep per night, 280 interruptions in sleep per week; & 14,560 interruptions per year.”

Click here to read the criminal complaint.