Walton v. Smith

Background

The court had previously allowed Denisha Walton and Justin Walton to proceed without paying the filing fee and dismissed their original complaint for failure to state a claim, while allowing them to amend. The plaintiffs then filed a Second Amended Complaint asserting ten claims against twenty defendants. They alleged that, after their 16-year-old daughter falsely reported that Justin Walton had molested her, they lost custody of their children. They asked the court to void state-court orders and try the issues before a jury.

Reasons for dismissal

The court first applied the Rooker-Feldman doctrine, which generally prevents a federal district court from reviewing or undoing a state-court judgment. The court had previously told the plaintiffs to provide case numbers and information about state-court custody proceedings so it could determine whether any claims were independent of those orders. Because the plaintiffs did not provide that information, the court found that their claims were subject to dismissal under the doctrine.

The court also addressed the fourteen defendants named in both the original complaint and the Second Amended Complaint. As to eleven of them, the plaintiffs had not added supporting facts. As to Mamie Wong, the court held that the alleged conduct occurred in connection with dependency proceedings and was protected by absolute immunity for social workers. As to Julia Ten Eyck, a court-appointed attorney for the plaintiffs’ children, the plaintiffs did not allege that she owed them a duty of care or that her conduct caused them harm. As to the John Muir Behavioral Health Center, the plaintiffs asserted a False Claims Act theory, but the court stated that it had already dismissed those claims because the plaintiffs were proceeding without a lawyer, and that ruling remained unchanged.

The newly named defendants were Joe Biden, Kamala Harris, Merrick Garland, Xavier Becerra, San Francisco County, and Margaret Pendergast. The court rejected the claims against the federal defendants under 42 U.S.C. §§ 1983, 1985, and 1986 because the plaintiffs did not allege facts showing that the federal officials acted together with state officials or knew about the challenged conduct. Claims based on individual liability under the Bivens doctrine were also dismissed because the circumstances did not fit the limited situations in which that doctrine applies. Tort claims against the federal defendants were dismissed because the plaintiffs did not allege compliance with the Federal Tort Claims Act’s administrative requirements.

The court dismissed the tort claims against San Francisco County because the plaintiffs did not allege that they had first presented those claims as required by the California Tort Claims Act. It also dismissed the remaining federal claims against the County because the plaintiffs did not adequately allege a county policy, custom, or practice that caused a constitutional violation. Finally, the professional-negligence claim against Margaret Pendergast, identified as the parents’ third appointed attorney, failed because the plaintiffs did not allege conduct that caused them harm.

Disposition

Judge Maxine M. Chesney dismissed the claims against all previously named defendants without further leave to amend. The court dismissed the claims against the newly named defendants with leave to amend because it believed some deficiencies might be curable. The court permitted the plaintiffs to file a Third Amended Complaint, if any, by November 1, 2024.