Nathaniel Brent v. Wayne Cty. Dep't of Human Servs.
901 F.3d 656
6th Cir.2018Background
- In Feb. 2010 Wayne County DHS removed the Brent children after social workers petitioned family court; parents allege false statements in the petition and improper rubber-stamped judicial approval.
- DHS caseworkers placed children in foster and institutional care (Methodist; Children’s Center supervised placements/visitation); parents allege medical mistreatment of son Robert while at Methodist.
- Plaintiffs filed a multi-defendant suit including federal §1983 and various state-law claims; protracted district-court proceedings produced multiple dismissals, amendments, interlocutory rulings, and appeals.
- Key procedural events: (1) district court dismissed Judicial Defendants under Rooker-Feldman/standing; (2) district court dismissed/treated some defendants as state actors or as arms of the state (Eleventh Amendment); (3) multiple immunity rulings under federal qualified/absolute immunity and Michigan state-law immunity (Martin and the GTLA).
- Sixth Circuit disposition: AFFIRM in part, REVERSE in part, and REMAND — holding (inter alia) that plaintiffs adequately pleaded that Methodist and Children’s Center could be state actors for §1983 purposes; affirming state/qualified-immunity rulings in other respects and granting Martin absolute immunity to individual state social workers for IIED/eavesdropping claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| District-court dismissal of claims against Judge Leslie Smith (rubber-stamp policy) | Brent: policy caused Fourth Amendment injury and is subject to federal challenge | Defendants: Rooker-Feldman/standing bars federal review of state-court orders; no standing for facial challenge | Court: Rooker-Feldman bars challenge as-applied to order; no standing to bring facial declaratory challenge — AFFIRM |
| Whether Methodist and Children’s Center are state actors for §1983 | Brent: entities performed state functions under DHS contracts and were entwined with state regulation and DHS supervision | Methodist/Center: private actors; not clothed with state authority | Court: pleaded facts create plausible close-nexus; REMAND for factual development on state-actor and §1983 merits — REVERSE dismissal |
| State social workers’ immunity (IIED/eavesdropping) under Michigan law (Martin) | Plaintiffs: Martin immunity no bar here (pre-petition acts, interns, conduct outside scope) | State Defs: Martin grants absolute immunity for initiating/monitoring child-placement proceedings | Court: Denial of Martin immunity was appealable; Martin grants absolute immunity to these social workers for IIED/eavesdropping; reverse denial and enter judgment for defendants — REVERSE/REMAND to re-enter judgment for Defs |
| Wenk and other social workers: absolute vs qualified immunity for preparing/ executing removal order and for in-home questioning/photographing | Plaintiffs: Wenk submitted false info, rubber-stamped order, executed a facially invalid order and exceeded consent during in-home interviews | Defs: absolute immunity for advocacy/judicial functions; qualified immunity for execution/removal and in-home policing actions | Court: absolute immunity for petitioning/testifying; qualified immunity applies to execution of removal — Wenk entitled to qualified immunity on execution (because right not clearly established); in-home questioning alleged against Robert did not show seizure or clearly established violation — MIXED (AFFIRM qualified immunity outcomes) |
| City of Detroit/Officers — reliance on family-court removal order; Monell failure-to-train/supervise; IIED and gross negligence claims | Plaintiffs: removal order was facially defective; officers used excessive force and violated internal DPD policy; municipal liability via custom/consent decree knowledge | City/Officers: order equivalent to warrant; reasonable reliance; statutory/gov’t immunity for discretionary acts; no Monell predicate | Court: order not so deficient to make reliance unreasonable; limited force/push not constitutionally excessive; statutory immunity bars IIED; Monell allegations insufficient; gross-negligence claim properly struck as recharacterized intentional-tort — AFFIRM |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S.) (explains the limited scope of Rooker-Feldman jurisdictional bar)
- Brentwood Acad. v. Tenn. Secondary Sch. Athletic Ass’n, 531 U.S. 288 (U.S.) (state-action close-nexus test for attributing private action to the state)
- West v. Atkins, 487 U.S. 42 (U.S.) (private contractors performing state obligations can act under color of state law)
- Imbler v. Pachtman, 424 U.S. 409 (U.S.) (absolute prosecutorial immunity principles informing immunity for analogous advocacy roles)
- Martin v. Children’s Aid Soc., 544 N.W.2d 651 (Mich. Ct. App. 1996) (Michigan rule granting absolute immunity to social workers for initiating/monitoring child-placement proceedings)
- Groh v. Ramirez, 540 U.S. 551 (U.S.) (warrant defects and the objective-reasonableness inquiry for executing officers)
- Barber v. Miller, 809 F.3d 840 (6th Cir.) (social worker absolute immunity for allegedly false statements in custody petitions)
- Kovacic v. Cuyahoga County Dept. of Children & Family Servs., 724 F.3d 687 (6th Cir.) (Fourth Amendment standards for seizure of children and social-worker police-role analysis)