Teeman v. State of Washington DSHS, 1:16-cv-03040

Background

On Sept. 11, 2014, four children living with Kevin Teeman and Andrea Lyons were removed after a 4‑month‑old (C.T.) was found to have a femur fracture; hospital referred the matter to DSHS and law enforcement.
DSHS social worker Staci Foster investigated; Yakima County Deputy Leo Hull (a law‑enforcement officer) took the children into protective custody at the scene citing probable cause and imminent risk.
The children were briefly placed with relatives; later medical review suggested osteogenesis imperfecta and DSHS dismissed dependency proceedings, returning the children to Plaintiffs on Sept. 30, 2014.
Plaintiffs sued DSHS and Foster, plus supervisors Perez, Chard, and Rocha‑Rodriguez, asserting 42 U.S.C. § 1983 claims (procedural due process/family unity, false presentation of evidence, unlawful seizure) and multiple state‑law tort claims.
Defendants moved for summary judgment; court deemed many plaintiff factual disputes unsupported by admissible evidence and treated those facts as undisputed.
Court granted defendants’ motion: DSHS dismissed as a state entity immune from § 1983 suit; individual defendants entitled to qualified immunity; state‑law claims barred or subject to limited liability protections under Washington law.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DSHS is a "person" under § 1983	DSHS is liable under § 1983 for constitutional violations	DSHS is an arm of the state and immune from § 1983 suit	DSHS is not a person under § 1983; Eleventh Amendment immunity applies (dismissed)
Whether removal of children violated Due Process / family unity	Foster and DSHS unlawfully separated family without warrant/court order	Removal was lawful because Deputy Hull (law enforcement) had probable cause and acted for imminent risk; Foster did not effectuate the seizure	No Fourteenth Amendment violation by Foster; defendants entitled to qualified immunity
Whether defendants presented false evidence/perjured testimony	Plaintiffs allege perjury, fabrication, suppression of exculpatory evidence	Plaintiffs offered no admissible evidence showing deliberate falsehood or causation	Plaintiffs failed the heightened showing; summary judgment for defendants
Fourth Amendment unlawful seizure (interview of children at school)	Interviewing children at school without consent/warrant violated Fourth Amendment	Plaintiffs lack standing to assert children’s Fourth Amendment rights; unclear established law	No Fourth Amendment relief for plaintiffs (lack standing); qualified immunity applies
State‑law tort claims (e.g., IIED, negligence, false imprisonment)	State tort claims against DSHS/employees	Eleventh Amendment, RCW limited liability for child‑protection acts; need gross negligence for liability	State claims dismissed/subject to limited liability; plaintiffs failed to show triable issues of gross negligence

Key Cases Cited

Scott v. Harris, 550 U.S. 372 (court must view facts and inferences in light most favorable to nonmoving party)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden shifting)
Anderson v. Liberty Lobby, 477 U.S. 242 (standard for genuine dispute of material fact)
Will v. Michigan Dept. of State Police, 491 U.S. 58 (states and state agencies not "persons" under § 1983)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework)
Ashcroft v. al‑Kidd, 563 U.S. 731 (scope of qualified immunity)
Saucier v. Katz, 533 U.S. 194 (two‑step qualified immunity analysis; context for clearly established law)
Jones v. County of Los Angeles, 802 F.3d 990 (9th Cir.) (parental right to family integrity and when child may be separated)
Hervey v. Estes, 65 F.3d 784 (9th Cir.) (heightened standard for false evidence claims against public employees)
Camreta v. Greene, 563 U.S. 692 (vacating part of Greene; limits on clearly established Fourth Amendment law regarding child interviews)