Olga C. v. County of Santa Clara
701 F. App'x 551
| 9th Cir. | 2017Background
- Plaintiff sued county social workers and the county under 42 U.S.C. § 1983 and Monell, alleging they committed extrinsic fraud on the Santa Clara County Juvenile Court during dependency proceedings that led to removal of her children.
- Defendants moved to dismiss, arguing the Rooker–Feldman doctrine deprived the federal court of jurisdiction and raising other defenses; the district court dismissed the federal claims under Rooker–Feldman and remanded state-law claims to state court.
- Plaintiff appealed the dismissal and remand to the Ninth Circuit. The panel had jurisdiction under 28 U.S.C. § 1291.
- The Ninth Circuit reviewed de novo whether Rooker–Feldman barred jurisdiction and whether the complaint stated plausible § 1983 and Monell claims under Rule 12(b)(6).
- The panel concluded Rooker–Feldman did not bar federal jurisdiction because Plaintiff alleged wrongful acts by adverse parties (extrinsic fraud), not errors by the state court, but found the complaint failed to plead sufficient facts to state plausible federal claims.
- The Ninth Circuit vacated the dismissal without prejudice (ordered dismissal with leave to amend), reversed the remand of state-law claims, and left other defenses (like collateral estoppel) for the district court on remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker–Feldman bars federal jurisdiction | Rooker–Feldman does not apply because she alleges defendants committed extrinsic fraud on the juvenile court | Rooker–Feldman requires dismissal because the federal suit attacks state court proceedings/outcome | Rooker–Feldman does not bar jurisdiction; plaintiff alleges wrongful acts by adverse parties (extrinsic fraud) not a de facto appeal |
| Whether complaint states a plausible § 1983 claim against social workers | Complaint alleges fabricated evidence and misconduct leading to children's removal | Complaint lacks specific factual allegations (which evidence, who acted) and defendants deny personal involvement | Complaint is deficient; dismissal required but with leave to amend to plead specific facts supporting extrinsic fraud theory |
| Whether Monell liability pleaded against county | County policies/culture caused the misconduct | Plaintiff failed to allege that misconduct resulted from official county policy or practice | Monell claim insufficiently pleaded; dismissal with leave to amend allowed |
| Whether absolute immunity or collateral estoppel bar claims | Plaintiff contends social workers are not absolutely immune for fabricating evidence | Defendants argue absolute immunity and collateral estoppel preclude suit | Absolute immunity not applicable to alleged fabrication; collateral estoppel was not decided on appeal (defendants waived by not raising earlier) |
Key Cases Cited
- Noel v. Hall, 341 F.3d 1148 (9th Cir. 2003) (Rooker–Feldman principles and limits)
- Kougasian v. TMSL, Inc., 359 F.3d 1136 (9th Cir. 2004) (distinguishing extrinsic fraud from a de facto appeal)
- Ebner v. Fresh, Inc., 838 F.3d 958 (9th Cir. 2016) (Rule 12(b)(6) review standard)
- Leadsinger, Inc. v. BMG Music Publ’g, 512 F.3d 522 (9th Cir. 2008) (leave to amend futility standard)
- Connick v. Thompson, 563 U.S. 51 (2011) (Monell and proof of policy or custom requirement)
- Jones v. Williams, 297 F.3d 930 (9th Cir. 2002) (personal participation requirement for § 1983)
- Beltran v. Santa Clara County, 514 F.3d 906 (9th Cir. 2008) (social workers not absolutely immune for fabricated evidence)