Youths held at the District's facilities for juvenile delinquents are subjected to vermin-infested housing that would not pass fire inspections, as well as beatings from their counselors, inadequate medical attention and insufficient educational programs, according to a lawsuit filed against the city yesterday by the D.C. Public Defender Service.

The suit, filed in D.C. Superior Court, alleges among other things that children must stuff cardboard into windows to keep out winter drafts, that often there are no qualified medical personnel on the premises, and that one of the principal psychiatrists responsible for evaluating and treating those with mental problems barely speaks English.

According to the suit, conditions at the city's Cedar Knoll and Oak Hill facilities -- which are in suburban Maryland and house about 200 youths, including a few young adults -- violate numerous city codes and federal laws and subject the youths to "cruel and unusual punishment" in violation of their constitutional rights.

The suit asks that the city be required to provide "humane and safe living conditions" at the compounds, as well as increases in staffing and educational and health services.

"The conditions have existed for some time without a sufficient response," said Frank Carter, director of the independent defender service, noting that his agency has been negotiating "several years" with city officials over problems at the facilities. "The need for improvement is immediate," Carter said. "It is our hope that the judiciary will bring the needed response."

Audrey Rowe, the city's commissioner of social services who is named in the complaint along with Mayor Marion Barry and other officials, said last night that she had not received a copy of the suit and declined to comment. She said she had heard rumors that such a suit was imminent.

The suit claims that conditions at Oak Hill and Cedar Knoll "inflict needless suffering" on the youths, who are "deprived of the educational, vocational, mental health and other social services that they so desperately need . . . . "

According to Public Defender Service attorneys, both facilities are extremely understaffed and there are severe shortages of workers trained to recognize and treat the educational, physical and therapeutic needs of the youths.

Children are randomly assigned to classes despite vast disparities in their educational levels and mental abilities, and some teachers are not qualified to pass muster in the city's public school system, according to the suit. The problems of mentally handicapped children in some cases are virtually ignored, and some children receive no schooling for months at a time, the suit contends.

Both facilities are maintained by the city's human services department, and the youths held there are city wards by court order for maximum two-year terms. Cedar Knoll is an unsecured facility housing children aged 12 to 15, while Oak Hill is surrounded by chain-link fences and barbed wire and holds youths between the ages of 15 and 20.

The suit contends the 70 to 100 children held at Cedar Knoll at any given time live in buildings that have large holes in walls and ceilings. "Most of the buildings have windows that either have broken glass . . . or cannot be closed because of faulty closing mechanisms," the suit states.

Walls have "large strips of peeling paint," and electrical sockets "are totally exposed and give electric shocks when used." Heating and plumbing fixtures are "old and deteriorated" and "regularly overflow," forcing cottages there to be evacuated.

Teachers there "have abandoned even the semblance of attending to all the students in their classes." Children in the maximum security unit "are not allowed to leave their cottage to attend school," and no teacher is sent to the cottage, the suit states.

Children listed as "borderline retarded" are sent to classes with normal students, the suit maintains. Psychiatric services "are virtually nonexistent," and the psychiatrist who works there has only a "limited facility with the English language."

"There is not a physician or even a registered nurse on duty twenty-four hours a day," according to the suit. One child who was assaulted in December and sustained "major lacerations" to his head was not taken to a hospital for nearly an hour because of a lack of transportation, the suit maintains. The suit describes an incident at Cedar Knoll last October in which a counselor "grabbed a 17-year-old by the throat and threw him against a wall" then "dragged him across the floor . . . . "

At Oak Hill, the suit contends, "many of the cottages fail to comply with fire safety requirements." Some fire extinguishers are empty, and keys to fire boxes and extinguishers are not kept on the premises, the suit alleges.

Cold air pierces the window frames in winter, and "the lack of air conditioning in the cottages renders the children's rooms almost unbearable" in the summer, according to the suit. The only vocational training there, the suit contends, is a course in barbering.

A youth who "suffers from major recurrent depression" and needs daily counseling received "no mental health services whatsoever" during five months of confinement, says the suit. Another had a tooth knocked out in a fight 18 months ago but received no medical attention until the next day, and the city has not replaced his tooth, the suit contends.