Sydney Rieman v. Gloria Vazquez, 96 F.4th 1085

Ms. Rieman’s newborn fell from a bed; she promptly sought medical care, and the incident was reported to San Bernardino County Child and Family Services (CFS).
Social workers Vazquez and Johnson investigated, but after failing to convince the family to take the child for further evaluation, they obtained a temporary detention warrant and attempted multiple unsuccessful attempts at service.
Social workers subsequently set a juvenile detention hearing but did not notify Ms. Rieman, instead falsely reporting to the Juvenile Court that her whereabouts were unknown.
Ms. Rieman and her family made repeated attempts to contact CFS, but received no notice of the hearing and did not attend; CFS was granted custody of her child, who was later returned after two months when dependency proceedings were dismissed.
Ms. Rieman sued under 42 U.S.C. § 1983, alleging violations of her Fourth and Fourteenth Amendment rights for failure to provide notice and for judicial deception.
Vazquez and Johnson moved for absolute and qualified immunity, which the district court denied; they appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Absolute Immunity for Social Workers	Immunity does not cover failing to give notice or providing false info; their acts were not discretionary prosecutorial acts.	Actions related to initiating dependency are covered by absolute immunity due to quasi-prosecutorial role.	No absolute immunity; failing to notify and providing false info are not covered by absolute immunity.
Qualified Immunity—Failure to Provide Notice	Right to notice was clearly established and deliberately ignored; no reasonable effort was made to notify.	Tried to serve prior to dependency hearing; law unclear if other notice methods were required.	No qualified immunity; right to notice was clearly established and violated.
Qualified Immunity—Judicial Deception	Providing false information to court about notice constitutes judicial deception under clearly established law.	Law not clear that misrepresenting parent's whereabouts is a due process violation; no specific case on these facts.	No qualified immunity; prohibition against judicial deception was clearly established.

Imbler v. Pachtman, 542 U.S. 409 (absolute immunity applies only to functions critical to the judicial process)
Beltran v. Santa Clara Cnty., 514 F.3d 906 (social workers not absolutely immune for investigatory conduct or making false statements in affidavits)
Ram v. Rubin, 118 F.3d 1306 (parents have due process right to notice and a hearing before custody deprivation)
Greene v. Camreta, 588 F.3d 1011 (right to be free from judicial deception in dependency proceedings)
Hardwick v. Cnty. of Orange, 844 F.3d 1112 (no circumstances allow government officials to bear false witness in dependency proceedings)
Costanich v. Dep't of Soc. & Health Servs., 627 F.3d 1101 (deliberately fabricating evidence in child abuse proceedings violates Due Process)