919 F.3d 1054
8th Cir.2019Background
- Mother (Calgaro) sued county, county public-health director, school district, school principal, and medical providers, alleging deprivation of parental rights under the Fourteenth Amendment for decisions about her minor child E.J.K.
- In 2015 E.J.K. moved out, obtained a letter from legal aid claiming emancipation, and presented it to agencies; St. Louis County provided assistance and E.J.K. obtained medical care and prescriptions without parental consent under Minnesota statutes permitting certain minors to consent.
- Park Nicollet and Fairview denied Calgaro access to E.J.K.’s medical records under Minnesota law; the school and principal refused access to educational records and participation in school decisions.
- Calgaro sought damages and declaratory/injunctive relief to bar defendants from providing services to her minor children absent a state-court adjudication of parental-rights scope.
- District court granted defendants’ dispositive motions, dismissed the complaint with prejudice; this appeal affirms that judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability (Monell) for County actions | County’s policies/customs caused deprivation by treating E.J.K. as emancipated and funding services | Single erroneous employee act does not show a municipal policy or custom | Dismissed: plaintiff failed to plead specific policy/custom sufficient for §1983 municipal liability |
| Individual liability of County director (Mirsch) | Director is final policymaker and thus liable | No allegation of Mirsch’s personal involvement; cannot be liable for subordinates’ acts | Dismissed: no personal-action allegations; Iqbal bars supervisory liability |
| Private medical providers as state actors under §1983 | Providers effectuated termination of parental rights by accepting minor consent, so acted under color of state law | Providers’ reliance on statutory consent does not convert them into state actors; only courts can terminate parental rights | Dismissed: providers not state actors; no §1983 claim against them |
| School officials’ and principal’s liability; parental access to records | District/Principal had policy/custom of denying notice/hearing and refused parental access to records and decisions | Plaintiff pled only a single incident; law does not clearly establish a parental constitutional right to all school records/participation | Dismissed: Monell claim inadequately pleaded; individual defendant entitled to qualified immunity |
| Relief (declaratory/injunctive) as to emancipated minor | Seeks injunction and declaration to prevent defendants from treating minors as emancipated without adjudication | E.J.K. is no longer a minor and completed school; no ongoing controversy; no reasonable expectation of recurrence for other children | Moot: claims for prospective relief dismissed (no capable-of-repetition exception met) |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (municipal liability requires policy or custom)
- Ashcroft v. Iqbal, 556 U.S. 662 (supervisory liability requires personal involvement)
- Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40 (state-action doctrine limits §1983 to actions under color of state law)
- Schmidt v. Des Moines Pub. Sch., 655 F.3d 811 (questioning scope of parental constitutional interest in school records)
- Stevenson v. Blytheville Sch. Dist. #5, 800 F.3d 955 (parents do not have clearly established rights to manage all educational details)
- Ashcroft v. al-Kidd, 563 U.S. 731 (qualified immunity framework)
- Murphy v. Hunt, 455 U.S. 478 (capable-of-repetition-yet-evading-review mootness exception)