Hartman v. State of Washington Department of Children Youth and Families
2:24-cv-00554
| W.D. Wash. | Jun 10, 2025Background
- Sophie Hartman adopted two children, C.H. and M.H. In 2019, a medical professional reported concerns about possible medical child abuse by Hartman.
- A Renton Police Department detective (O’Rourke) investigated and, based on medical concerns, sought and executed search warrants at Hartman’s home and removed the children without a court order.
- Criminal and dependency proceedings followed. Ultimately, criminal charges against Hartman were reduced and later dropped; decision-making authority over C.H. was restored to Hartman after two years.
- Hartman and the children brought claims against the Renton Police, O’Rourke, and others, asserting both federal civil rights and state law tort claims related to the investigation, search, seizure, and removal.
- Defendants moved for summary judgment; the court’s decision resolves which claims proceed and which are dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial Deception (4th/14th Am.) | O’Rourke fabricated or recklessly omitted info in affidavits to court. | All evidence relied on reliable medical sources; no deliberate deception. | Summary judgment for defendants; plaintiffs failed to show deliberate fabrication. |
| Unlawful Search & Seizure | Warrants lacked particularity; search of devices/records was overbroad. | Warrants were specific, supported by probable cause, and correctly limited. | Summary judgment for defendants; warrants were constitutionally sufficient. |
| Unlawful Seizure of Children w/o Order | No imminent danger justified removing C.H. and M.H.; no emergency at home. | Serious allegations of medical child abuse; relied on doctor’s letter. | Denied summary judgment: factual dispute whether exigent circumstances existed. |
| State Law Tort Immunity & Gross Negligence | O’Rourke’s investigation/removal was grossly negligent (failure to contact doctors, delayed response, admitted no emergency). | Acted on reliable medical info; actions not grossly negligent. | Denied summary judgment: material fact dispute on gross negligence precludes immunity. |
| Defamation | Claim time-barred; conceded by plaintiff after review. | Two-year statute of limitations expired before filing. | Summary judgment for defendants; claim time-barred. |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
- Ashcroft v. al-Kidd, 563 U.S. 731 (qualified immunity principles)
- Chism v. Washington, 661 F.3d 380 (judicial deception, reliance on warrants)
- Gausvik v. Perez, 345 F.3d 813 (standards for deliberate fabrication)
- Wallis v. Spencer, 202 F.3d 1126 (requirements for warrantless child removal)
- Ram v. Rubin, 118 F.3d 1306 (reasonable inference of imminent danger in child removal)