Wooten v. Sturts, 2:25-cv-00256

Bailey Wooten, an Ohio resident proceeding pro se, sued various parties related to the temporary removal of her child from her custody, alleging violations of federal constitutional and statutory rights.
The magistrate judge initially recommended dismissing Wooten’s complaint for failure to state a claim but allowed her to amend and granted in forma pauperis and electronic filing rights.
Wooten filed an Amended Complaint addressing some deficiencies; the court vacated the recommendation of dismissal and proceeded to re-screen the claim.
After review, the court found Wooten could proceed solely on her Fourteenth Amendment due process claims against two defendants: caseworker Chris Jones and supervisor Tara Sturts of Morrow County Job and Family Services.
The court dismissed all other claims and defendants, finding insufficient factual allegations, immunity, lack of standing, and the absence of private rights of action under cited statutes.
Several motions (to compel discovery, for counsel, to seal documents, etc.) were ruled on, with some granted in part (e.g., sealing and service) and most denied or denied as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due process rights under the Fourteenth Amendment	Removal of child without valid court order	(Not provided)	Plaintiff can proceed against Jones and Sturts
Municipal liability under §1983	County policy/custom caused rights violation	No policy/custom alleged	Dismissed—lack of policy/custom allegations
Judicial immunity for state judge/magistrate	Actions caused harm during custody proceedings	Absolute judicial immunity	Dismissed—judicial immunity applies
Sixth Amendment effective assistance of counsel	Ineffective representation in civil case	Sixth Amendment inapplicable	Dismissed—not applicable to civil cases
Claims under federal statutes (ADA, §1985, CAPTA, etc.)	Statutes support private claims for relief	No private right of action	Dismissed—no private right of action/insufficient facts
Exemption from PACER fees/ancillary motions	Need for fee/counsel/discovery assistance/sealing	Procedural/practical bases	Mostly denied or denied as moot, partial sealing granted
Leave to file Second Amended Complaint	Additional causes of action merit amendment	Futility	Denied—amendment would be futile under pleading standards

Pierson v. Ray, 386 U.S. 547 (1967) (establishing that judges are absolutely immune from civil liability when acting within their judicial capacity)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (setting the plausibility pleading standard; complaints must offer more than labels and conclusions)
Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (local governments are liable under §1983 only for constitutional violations resulting from official policy/custom)
Mireles v. Waco, 502 U.S. 9 (1991) (clarifying the scope of judicial immunity and its exceptions)
Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints construed liberally, but still must state a claim)
Linda R.S. v. Richard D., 410 U.S. 614 (1973) (private citizens lack a judicially cognizable interest in prosecution decisions)
Thompson v. Thompson, 484 U.S. 174 (1988) (private right of action not supported unless Congress clearly intended it in statute)