Nathaniel Brent v. Wayne Cty. Dep't of Human Servs.

Summary

The Sixth Circuit held that the Rooker-Feldman doctrine barred claims against a family court judge for past application of an alleged rubber-stamping policy on child-removal orders, and that the plaintiff lacked standing for a forward-looking challenge. The court ruled that private foster-care agencies (Methodist Children’s Home and The Children’s Center) may be state actors under § 1983 when they contract with the state to fulfill its constitutional duty to protect children in custody, reversing dismissal of those claims. Social workers are entitled to absolute immunity for preparing and filing removal petitions (including knowingly false statements) but only qualified immunity for executing the removal order; qualified immunity applied because the right was not clearly established. The court also affirmed that Wayne County DHS is an arm of the state entitled to Eleventh Amendment immunity, that the Children’s Center had not waived Martin immunity under Michigan law, and that Robert Brent’s Fourth Amendment claims failed because he was not seized during home visits.

Holdings

1. The district court lacked jurisdiction over Brent's claim against Judge Smith because the Rooker-Feldman doctrine bars claims seeking redress for past injuries caused by a state-court order, and Brent lacked standing to bring a forward-looking facial challenge.
2. Plaintiffs plausibly alleged that Methodist and Children's Center are state actors because they contracted with the state to fulfill constitutional obligations to protect children in state custody, creating a close nexus with the state.
3. The district court properly barred Robert's IIED claim as futile because the allegations did not meet the high standard for extreme and outrageous conduct under Michigan law.
4. Children's Center is entitled to absolute immunity under Martin v. Children's Aid Soc. for state-law claims because it was engaged in initiating and monitoring child placement proceedings.
5. Wayne County DHS is an arm of the state entitled to Eleventh Amendment immunity because state law controls its operations, funding, and liability.
6. Social workers Wenk, Sampson, and Lamar are entitled to absolute immunity for preparing and submitting the removal petition and for serving as complaining witnesses, but Wenk is entitled only to qualified immunity for executing the order. Qualified immunity applies because the right was not clearly established at the time.
7. Robert's Fourth Amendment claims are barred by qualified immunity because the allegations do not show a clearly established violation; Robert was not seized within the meaning of the Fourth Amendment during the home visits.
8. Plaintiffs may not bring damages claims under the Michigan Constitution against individual government employees, and the cited child protection statute does not create a private right of action.
9. Trice is entitled to governmental immunity under the GTLA because her failure to report was not the proximate cause of Robert's injuries.
10. State defendants are entitled to absolute immunity under Martin for IIED and eavesdropping claims because the conduct occurred in the course of child protection proceedings.
11. City defendants are entitled to qualified immunity because the removal order was not facially invalid and the use of force was reasonable. The Monell claim fails for lack of an underlying constitutional violation and insufficient pleading of a custom or policy.

Questions Presented

1. Whether the district court erred in dismissing claims against Judge Smith under the Rooker-Feldman doctrine and for lack of standing.
2. Whether Methodist Children's Home Society and The Children's Center are state actors for purposes of 42 U.S.C. § 1983.
3. Whether Robert Brent's IIED claim against Methodist was properly barred as futile.
4. Whether The Children's Center is entitled to absolute immunity under Martin v. Children's Aid Soc. for state-law claims.
5. Whether Wayne County DHS is an arm of the state entitled to Eleventh Amendment immunity.
6. Whether social workers Wenk, Sampson, and Lamar are entitled to absolute or qualified immunity for their roles in the removal order.
7. Whether Robert Brent's Fourth Amendment claims against social workers for home visits are barred by qualified immunity.
8. Whether state constitutional claims are viable under Michigan law.
9. Whether Trice is entitled to governmental immunity under the GTLA for failure-to-report claim.
10. Whether state defendants are entitled to absolute immunity under Martin for IIED and eavesdropping claims.
11. Whether City defendants are entitled to qualified immunity and whether Monell claim fails.

Disposition

other