Alicia Hatfield v. Amanda Berube
714 F. App'x 99
| 3rd Cir. | 2017Background
- In March 2012 Allegheny County obtained temporary emergency protective custody orders for Alicia Hatfield’s four children; dependency proceedings followed and children were placed with relatives or returned to Hatfield as proceedings concluded.
- While state dependency proceedings were pending, Hatfield sued in federal court (W.D. Pa.) alleging § 1983 claims (Fourth and Fourteenth Amendment), HIPAA and Privacy Act violations, and intentional infliction of emotional distress (IIED) against county officials, CYF, its director, and two caseworkers (Berube and Tennant), seeking injunctive, declaratory, and monetary relief.
- The district court dismissed or granted summary judgment for defendants, finding lack of personal involvement by county executives, failure to state a Monell claim, Rooker–Feldman bar to challenges of state-court orders, absolute immunity for prosecutorial acts by child-welfare workers, qualified immunity on Fourth Amendment claim, and statutory immunity under Pennsylvania’s PSTCA for IIED.
- Hatfield appealed; the Third Circuit reviewed de novo and summarily affirmed the district court’s judgment.
- The court analyzed (a) personal involvement requirement for § 1983, (b) municipal liability/failure-to-train, (c) Rooker–Feldman limits on reviewing state-court judgments, (d) absolute and qualified immunities for child-welfare actors, and (e) non-cognizability of HIPAA and inapplicability of the federal Privacy Act to state actors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal involvement of Fitzgerald & Sturdivant in § 1983 claims | Hatfield alleged supervisory liability for removal and procedures | Defendants lacked any personal involvement in alleged constitutional deprivations | Dismissed for failure to plead facts showing personal involvement; leave to amend given but no cure |
| Municipal (Monell) failure-to-train | CYF failed to train employees about parents’ constitutional rights, policies, HIPAA, Mental Health Procedures Act | No specific training defect alleged that caused Hatfield’s injuries or showed deliberate indifference | Dismissed: plaintiff failed to identify specific training deficiency causally linked to injury |
| Rooker–Feldman and scope of federal review | Federal suit sought relief reversing state-court custody determinations and complained of procedures leading to those rulings | Federal courts lack jurisdiction to directly review state-court judgments; claims traceable to state judgments are barred | Claims seeking direct review of state-court custody orders barred by Rooker–Feldman; separate claims against workers’ independent actions survive jurisdictionally |
| Immunities & constitutional claims (absolute/qualified; due process; Fourth Amendment; notice) | Berube/Tennant engaged in investigatory misconduct, coerced consent to home inspection, denied procedural and substantive due process; IIED and privacy claims | Defendants invoke absolute immunity for judicial/prosecutorial functions, qualified immunity for investigatory acts, statutory municipal immunity under PSTCA; HIPAA provides no private right; Privacy Act does not apply to state actors | Absolute immunity applies to acts preparing/prosecuting dependency proceedings and supervisory approvals; Berube’s outside-the-court investigatory acts are not absolutely immune but her warrantless inspection was not clearly unconstitutional (qualified immunity); no substantive due process shock-the-conscience; adequate notice shown; HIPAA and Privacy Act claims dismissed; IIED barred by PSTCA |
Key Cases Cited
- Barefoot Architect, Inc. v. Bunge, 632 F.3d 822 (3d Cir. 2011) (standard of review for dismissal and summary judgment)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard for Rule 12(b)(6))
- Rode v. Dellarciprete, 845 F.2d 1195 (3d Cir. 1988) (personal involvement requirement under § 1983)
- Monell v. Dep’t of Soc. Servs. of N.Y., 436 U.S. 658 (U.S. 1978) (municipal liability for constitutional violations)
- City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (failure-to-train deliberate indifference standard)
- Reitz v. Cty. of Bucks, 125 F.3d 139 (3d Cir. 1997) (causal nexus and deliberate indifference in training claims)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (Rooker–Feldman doctrine explained)
- Ernst v. Child & Youth Servs. of Chester Cty., 108 F.3d 486 (3d Cir. 1997) (absolute immunity for child-welfare employees in prosecutorial functions)
- B.S. v. Somerset Cty., 704 F.3d 250 (3d Cir. 2013) (limits of Rooker–Feldman and immunity for child-welfare recommendations)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (qualified immunity framework)