Edenfield v. Gateway Behavioral Health Services
2:16-cv-00170
S.D. Ga.May 15, 2017Background
- Quincy Edenfield, an adult with severe autism and intellectual disabilities, received housing, transportation, and behavioral services from Gateway Behavioral Health Services since May 2012; his mother Cheryl is his guardian.
- Cheryl observed unexplained wounds on Quincy on multiple occasions and questioned Gateway staff but was not told he was being abused; internal early investigations did not reveal abuse.
- On February 27–29, 2016, Gateway staff reported that employee Errol Wilkins had repeatedly hit Quincy; Gateway investigated, substantiated the reports, and terminated Wilkins.
- Cheryl sued Gateway in state court asserting state-law torts (failure to train/supervise, negligent retention, assault and battery, and later fraud) and a 42 U.S.C. § 1983 claim; Gateway removed the case and moved for judgment on the pleadings; Cheryl moved to amend to add Wilkins and a fraud count.
- The court granted judgment on the pleadings as to Cheryl’s state-law tort claims (finding sovereign immunity), denied judgment as to her § 1983 claim (finding Gateway is a "person" under § 1983 after Miller), and denied judgment as to her contract-breach claim (finding a plausible written contract exists). Cheryl’s motion to amend was denied as futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Georgia sovereign immunity bars Cheryl's state-law tort claims | Cheryl: O.C.G.A. § 50-21-23(a) waives immunity for employee torts, so tort claims (failure to train/supervise, negligent retention, assault/battery, fraud) may proceed | Gateway: As a state agency/community-service board, sovereign immunity applies; statutes expressly preserve immunity for losses resulting from assault or battery | Court: Granted judgment for Gateway; sovereign immunity bars the state-law tort claims because underlying conduct arose from assault/battery |
| Whether Gateway is subject to suit under 42 U.S.C. § 1983 | Cheryl: § 1983 claim based on Fourteenth Amendment; Gateway should be treated as a person subject to suit | Gateway: Argues it is a state agency/arm of the state and thus not a "person" under Will v. Michigan Dept. of State Police | Court: Denied judgment on this claim; relying on Eleventh Circuit precedent (Miller), Gateway is not an arm of the state and § 1983 claim survives |
| Whether Georgia waived immunity for breach of a written contract | Cheryl: She produced an orientation checklist and related documents evidencing a written behavioral-services contract for Quincy | Gateway: Challenges existence/validity of a written contract binding the state entity | Court: Denied judgment on the contract claim; the documents plausibly constitute a written contract, so sovereign immunity waiver for written contracts applies |
| Whether amendment to add Wilkins and a fraud claim is permissible | Cheryl: Seeks to add Wilkins and a fraud count based on the abuse and alleged misrepresentations | Gateway: Opposes amendment; argues claims would be futile because sovereign immunity bars the state-law torts and the fraud claim arises from same underlying conduct | Court: Denied amendment as futile because the proposed state-law fraud claim is barred by sovereign immunity |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard: factual allegations must plausibly state a claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
- Will v. Michigan Dep't of State Police, 491 U.S. 58 (states and state agencies are not "persons" under § 1983)
- Foman v. Davis, 371 U.S. 178 (leave to amend should be freely given unless futility or other factors justify denial)
- Executive 100, Inc. v. Martin County, 922 F.2d 1536 (11th Cir.) (12(c) standard: judgment on the pleadings when no set of facts entitles plaintiff to relief)