Asleep on the top bunk in his room at the Glen Mills Schools, the boy thought he was having a dream that he was falling out of bed.

But the teenager from Michigan awoke to realize that school staff members were pulling him from the bed and slamming him to the floor, where they jumped on him and spit on his face.

The teenager wanted to tell his mother about the beatings he received from his counselors at the Delaware County school for court-ordered boys. But staff monitored his phone calls, threatened they would “make it worse” for him if he told, and disconnected the phone line when he tried to describe the abuse, according to a class-action suit filed in federal court Wednesday.

The lawsuit, filed by local civil rights attorney David Rudovsky in partnership with Berger Montague, a national class-action law firm based in Philadelphia, seeks unspecified compensation and damages for boys who were abused as students at the Glen Mills Schools, the oldest existing U.S. reform school.

The attorneys also are asking the court to compel Glen Mills to turn over all of its records from the last 20 years pertaining to the abuse of students, so that its victims and state and law enforcement officials alike can review them. They also are demanding that Glen Mills admit it violated the state’s mandatory reporting requirements for child abuse.

The complaint is brought by two former students, now 17 and 18, and one of their mothers under pseudonyms to protect their privacy. Shanon Carson, a managing shareholder of Berger Montague, said dozens of other individuals reporting abuse at Glen Mills already have contacted the attorneys, and the firm expects to hear from many more former students.

“The lawsuit will shine a light on what occurred over many years at the School and will begin our search for answers,” Carson said in a statement. “We encourage any person or family member of any child who was a student at The Glen Mills Schools and who was abused, to come forward and report the abuse to us in a confidential and safe environment so that our team can investigate it thoroughly and properly and obtain the truth about what happened.”

Last month, an Inquirer investigation found that Glen Mills counselors routinely beat the boys in their care, then used threats to keep them quiet about the abuse they endured. The school’s leaders failed to protect students by improperly vetting and training its counselors and insulating themselves from abuse complaints.

On Monday, the Pennsylvania Department of Human Services issued an emergency removal order for all boys remaining at Glen Mills after the state’s investigation corroborated The Inquirer’s reporting. The state Department of Education also said Wednesday it was directing school districts to stop placing students in Glen Mills’ alternative education program, a separate service on the same campus.

Aimee Tysarczyk, a spokesperson for Glen Mills, said the school’s counsel had yet to review the lawsuit and was unable to comment on it Wednesday. She said the school planned to appeal the state’s removal order “and looks forward to sharing its side of the story and further details when the appeal is filed and shared with the public.”

“The school takes recent allegations seriously and has a zero-tolerance policy for these types of alleged actions,” Tysarczyk said in an email. “Our first priority has and always will be the safety of our students, so that they may lead full and productive lives.”

The teenager from Muskegon County, Mich. — dubbed Billy Miller — was 16 when a judge sent him to Glen Mills in 2016, according to the lawsuit. Billy was “routinely and severely abused” for several months, receiving frequent beatings from staff, who slammed him against walls and punched him.

Even though staff prevented him from describing the abuse to his mother during their phone calls, she noticed he seemed different, and became afraid for his safety. Billy’s parole officer arranged to transfer him to a different program. “The request was granted and when Mother Miller arrived at the School to pick up her son, Billy had a newly-broken nose, which was the result of being punched in the face by School staff,” the complaint reads.

The other plaintiff, called Charlie Jones, was 17 when he violated his probation and was sent from his Wilkes-Barre home to Glen Mills in 2018, according to the lawsuit.

Soon after, as he left the restroom one morning, Charlie was assaulted by three Glen Mills staffers and suffered three broken ribs. His offense, he says he was told, was using the bathroom before 10 a.m.

Staff also encouraged Charlie to fight with another student, according to the complaint, “and as a result, Charlie was beaten, had difficulty breathing, developed large bruises and welts, and suffered additional pain from his already broken ribs.” Glen Mills staff refused to give him medical attention “and advised him that he should lie and tell anyone who asked about his injuries that they occurred during a football practice.”

The complaint describes how Glen Mills’ beautiful campus and “pastoral setting” belie a reality of violence and cover-ups. At multiple points, it cites The Inquirer’s reporting. It also quotes a 2001 report from the Utah Division of Youth Corrections that, in seeking to evaluate out-of-state placements for youth, documented physical abuse at Glen Mills.

One Utah boy said he saw staff knock another student down the stairs, breaking his leg, over “disrespect to staff.” Another boy described being beaten and thrown on his head by a staff member who demanded he scrub a bathroom clean: “He starts knocking my brains out.” The students also said staff intercepted their letters to prevent abuse reports from getting home to Utah; boys who told were “beat down."

The complaint says that Glen Mills, in failing to keep its students safe, violated the Fourth, Eighth, and 14th Amendments to the U.S. Constitution. It also charges the school with negligence and infliction of emotional distress.

The complaint is brought against the Glen Mills Schools and “John Does 1-100," which refers to any employees or contractors who abused students. The “class” for the plaintiffs is defined as “all persons who have attended The Glen Mills Schools and who suffered physical abuse or are at risk of suffering physical abuse.”

“Under its veneer of civility," the report reads, “there is a Dickensian ‘culture of violence’ and intimidation at the School that has severely impacted Plaintiffs and other children."