Lorraine Patterson v. Arizona Department of Economic, 689 F. App'x 565

Patterson, proceeding pro se, sued over a dependency proceeding that removed her daughter from custody, bringing claims under 42 U.S.C. § 1983 against more than a dozen defendants (state agency, county, city, police department, prosecutors, social workers, and various individuals).
The district court dismissed the complaint under Rule 12(b)(6); Patterson appealed.
The panel reviewed the dismissals de novo and considered sovereign and absolute immunity defenses, municipal liability (Monell) pleading standards, causation for individual defendants, and amendment denial for undue delay.
The district court barred claims against the Arizona Department of Economic Security on Eleventh Amendment grounds and dismissed claims against Maricopa County, the City of Mesa, and Mesa Police Department for failure to plead a municipal policy or custom causing a constitutional violation.
The district court dismissed claims against a prosecutor (Hansen) based on prosecutorial immunity and dismissed several individual defendants for failure to allege causation; it also dismissed several social workers based on asserted absolute/quasi-judicial immunity.
On appeal the Ninth Circuit affirmed most dismissals but reversed dismissal as to several social workers accused of making false statements or fabricating evidence, and remanded those claims for further proceedings; the court also denied leave to file another amended complaint for undue delay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
State agency immunity (Eleventh Amendment)	Patterson sought relief against Arizona Department of Economic Security for actions in dependency case.	State agency immune from suit in federal court absent consent.	Dismissal affirmed; Eleventh Amendment bars the suit.
Municipal liability (Monell)	Patterson alleged county/city/police liability for constitutional harms.	Plaintiffs failed to plead a policy/custom causing constitutional violation.	Dismissal affirmed for failure to allege Monell claim.
Prosecutorial immunity	Patterson alleged prosecutor actions caused deprivation of rights.	Prosecutor entitled to absolute/quasi-prosecutorial immunity for initiating/pursuing dependency proceedings.	Dismissal affirmed; prosecutorial immunity applies.
Social workers' absolute immunity for quasi-judicial acts	Patterson alleged social workers fabricated evidence and made false statements in dependency proceedings.	Defendants claimed absolute immunity as quasi-judicial actors.	Reversed as to social workers accused of fabricating evidence/false statements; such claims are not barred by absolute immunity and were remanded.
Leave to amend (undue delay)	Patterson sought leave to file a fourth amended complaint.	District court denied for lack of good cause and undue delay.	Denial affirmed; no abuse of discretion.

Edwards v. Marin Park, Inc., 356 F.3d 1058 (9th Cir. 2004) (standard for de novo review of Rule 12(b)(6) dismissal)
Taylor v. List, 880 F.2d 1040 (9th Cir. 1989) (Eleventh Amendment bars suits against states and state agencies)
AE ex rel. Hernandez v. County of Tulare, 666 F.3d 631 (9th Cir. 2012) (pleading requirements for municipal liability under Monell)
Meyers v. Contra Costa Cty. Dep’t of Soc. Servs., 812 F.2d 1154 (9th Cir. 1987) (absolute immunity for quasi-prosecutorial functions in child dependency proceedings)
Baker v. McCollan, 443 U.S. 137 (U.S. 1979) (§ 1983 liability requires causation by the public official)
Beltran v. Santa Clara County, 514 F.3d 906 (9th Cir. 2008) (social workers not entitled to absolute immunity for fabricated evidence or false statements)
Hardwick v. County of Orange, 844 F.3d 1112 (9th Cir. 2017) (reaffirming no absolute immunity for social workers alleging fabrication/false statements)
Chodos v. West Publ’g Co., 292 F.3d 992 (9th Cir. 2002) (standards for denying leave to amend based on undue delay)
Monell v. Department of Social Services of New York, 436 U.S. 658 (U.S. 1978) (municipal liability framework)