Gatlin v. Contra Costa County

Background

The court had previously denied the County defendants’ motion for judgment on the pleadings concerning case-planning claims in the Fourth and Fifth Causes of Action in plaintiffs’ Second Amended Complaint. The County defendants then obtained permission to seek reconsideration based on the Supreme Court’s June 26, 2025 decision in Medina v. Planned Parenthood South Atlantic.

The claims concern case-planning provisions of the federal Adoption Assistance and Child Welfare Act, codified at 42 U.S.C. §§ 671(a)(16) and 675(1). In Henry A. v. Willden, the Ninth Circuit had recognized that foster children could enforce those provisions under 42 U.S.C. § 1983, the federal civil-rights statute that allows enforcement of certain federal rights against state or local actors.

Arguments and Analysis

The County defendants argued that Medina made Henry A. no longer valid. They contended that the case-planning provisions did not create an individual federal right enforceable under § 1983.

The court explained that the Supreme Court’s decisions in Gonzaga University v. Doe and Talevski require a federal spending statute to unambiguously confer an individual right before it can be enforced under § 1983. The court also explained that Medina rejected continued use of the earlier three-part test from Blessing v. Freestone and reaffirmed Gonzaga as the governing method.

The court nevertheless concluded that Henry A. had not been clearly overruled. Although Henry A. applied both the Blessing test and Gonzaga, it relied on Gonzaga in finding that the case-planning provisions used rights-creating and mandatory language. The court found that any tension between Henry A. and Medina did not meet the high standard required to treat the Ninth Circuit decision as effectively overruled.

The County defendants also argued that the case-planning provisions could not be enforced against a municipality such as the County. The court said it had already rejected that argument and that the County was improperly trying to relitigate it through reconsideration. The court also rejected the County’s assertion that Henry A. did not involve a claim for monetary damages, noting that the plaintiffs in that case had brought a damages claim under different provisions concerning records.

Disposition

Judge Susan Illston denied the County defendants’ motion for reconsideration of the order denying their motion for judgment on the pleadings. The opinion does not otherwise resolve the underlying case-planning claims.