Muncy v. Muncy
5:24-cv-00272
| E.D. Ky. | May 16, 2025Background
- Plaintiff Meghan Muncy alleged a broad conspiracy involving her ex-husband, medical professionals (including Dr. Samuel Potter and Dr. Rachèle Yadon), and others to deprive her of custody of her children.
- Muncy specifically claimed Potter and Yadon, doctors at University of Kentucky Psychiatric and Behavioral Healthcare, fabricated and misused her psychiatric records, and shared confidential information without consent.
- She asserted these actions violated her constitutional rights, formed part of a civil conspiracy, and constituted intentional infliction of emotional distress.
- Muncy did not respond to the motion to dismiss, but the court evaluated the merits regardless.
- The court dismissed the claims against Potter and Yadon, finding Muncy failed to allege sufficient facts to support any legal claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Conspiracy to deprive parental rights | Doctors conspired to deprive her of custody via fabricated records | Allegations are vague; no facts tying them to custody action | Dismissed; no plausible claim |
| Due process & familial association violations | Improper use/sharing of records violated her constitutional rights | No facts that defendants knew of, or acted to affect, custody rights | Dismissed; insufficient factual basis |
| Unlawful disclosure of medical information | Disclosure without consent violated her rights under HIPAA | No private right of action under HIPAA; no other independent legal basis alleged | Dismissed; not a viable claim |
| Intentional infliction of emotional distress | Defendants’ conduct was extreme and outrageous | Conduct was not extreme or outrageous by legal standard | Dismissed; conduct not legally outrageous |
Key Cases Cited
- Kottmyer v. Maas, 436 F.3d 684 (6th Cir. 2006) (recognizing parents’ fundamental interest in family integrity)
- Troxel v. Granville, 530 U.S. 57 (2000) (Supreme Court decision on parental rights under due process protections)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard requires sufficient facts to state a claim)