Terenzio v. Urena

Summary

The United States Court of Appeals for the First Circuit affirmed dismissal of claims brought by representatives of veterans who died after contracting COVID-19 at the Soldiers' Home in Chelsea, Massachusetts. The court held that the complaint did not plausibly allege that the defendant officials directly caused the alleged harms or establish an applicable exception to that requirement, and that qualified immunity barred the claims. The opinion also addressed special-relationship and state-created-danger theories under substantive due process.

Holdings

1. As a general matter, a substantive due process claim requires a plaintiff to plausibly allege that the state actor named as the defendant directly caused the alleged harm. The complaint's allegations that the defendants failed to protect residents from COVID-19 and failed to provide adequate living conditions did not allege that the defendants directly harmed the veterans.
2. A plaintiff may sometimes state a substantive due process claim without alleging that the defendant directly caused the harm by showing either a special relationship imposing an affirmative duty to protect or that the defendant created the danger that resulted in harm by a private actor. The plaintiffs did not adequately plead or rely on either exception on appeal.
3. The defendants were entitled to qualified immunity at the motion-to-dismiss stage because the complaint failed to plausibly allege a federal constitutional violation and did not show that the alleged conduct contravened clearly established law.

Questions Presented

1. Whether the complaint plausibly alleged that the defendants directly caused the veterans' alleged constitutional injuries or satisfied an exception to the general direct-causation requirement for substantive due process claims.
2. Whether the defendants were entitled to qualified immunity because the complaint failed to allege a constitutional violation and failed to show that the alleged conduct violated clearly established law.
3. Whether the district court properly dismissed the COVID-19-response and living-conditions claims under Rule 12(b)(6).

Disposition

affirmed