Williams v. County Of Monterey

Background

Monia Williams brought the action individually and as guardian ad litem for her minor children, L.S. and Q.S. The children were removed from Williams’s home after a report of suspected sexual abuse of L.S. by Williams’s uncle. The children remained outside the home for approximately three months, and the juvenile dependency proceedings were dismissed after a contested trial.

The complaint asserted six federal civil-rights claims under 42 U.S.C. § 1983 and a state-law claim for intentional infliction of emotional distress. Claims 6 and 7 were asserted against Santa Cruz County social workers Marcos Estrada and Josefina Duran. Claim 6 alleged a Fourteenth Amendment substantive due-process violation involving the family’s association and asserted that Estrada and Duran submitted fraudulent reports to the juvenile dependency court, causing the continued separation of Williams and the children. Claim 7 alleged intentional infliction of emotional distress.

Motion to Dismiss Standard

Estrada and Duran moved under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint states a legally sufficient claim. The court accepted well-pleaded allegations as true for purposes of the motion but required enough factual matter to make liability plausible. The court noted that the complaint did not attach Estrada’s reports or identify their specific contents, did not state what materials Estrada reviewed or whether he read the transcripts, and did not describe the alleged conspiracy or Duran’s conduct beyond directing Estrada to stop watching the body-camera videos.

Claim 7: Intentional Infliction of Emotional Distress

The court held that California Government Code sections 820.2 and 821.6 could be considered for the state-law claim, although state statutory immunities do not apply to federal civil-rights claims. Section 820.2 generally protects discretionary decisions by public employees, while section 821.6 protects certain prosecutorial or quasi-prosecutorial actions, including specified child-abuse investigations and dependency proceedings.

The court concluded that the complaint did not identify conduct by Estrada or Duran showing that they included false statements or misrepresentations in reports to the juvenile court. The allegation that Estrada’s jurisdiction report failed to disclose that the children had not been qualified did not allege that he knew this fact or that it was exculpatory. The court therefore found that the allegations at most suggested an inadequate investigation, which fell within the asserted state-law immunities. The court also found that the complaint did not allege specific facts that would trigger the exception for malicious perjury, fabrication of evidence, failure to disclose known exculpatory evidence, or obtaining testimony through duress or undue influence.

The motion to dismiss Claim 7 was granted with leave to amend on the ground that the claim appeared barred by sections 820.2 and 821.6 and that the complaint did not allege facts supporting the statutory exception.

Absolute Immunity

The court denied dismissal of Claims 6 and 7 based on absolute, quasi-judicial immunity. That immunity protects social workers when they perform quasi-prosecutorial or quasi-judicial functions in juvenile dependency court, but it does not protect investigative or administrative conduct or conduct outside the social worker’s legitimate advocacy role.

The court found that the allegations that Estrada stopped reviewing body-camera footage after watching only one video at Duran’s direction and failed to conduct the required independent investigation, viewed in the plaintiffs’ favor, described investigative and administrative activity. The court therefore held that absolute immunity did not provide a basis for dismissal at this stage.

Claim 6: Fourteenth Amendment and Qualified Immunity

The court granted the motion to dismiss Claim 6 based on qualified immunity, with leave to amend. Qualified immunity generally protects government officials from damages unless their conduct violated a constitutional right that was clearly established at the time.

The court found that the complaint, as pleaded, alleged at most that Estrada and Duran failed to conduct an adequate investigation before preparing reports. It did not allege facts showing a constitutional violation. The court explained that negligent conduct causing unintended harm does not by itself violate the Due Process Clause. Although the plaintiffs relied on a prior decision recognizing a right to be free from deception in protective-custody proceedings, such a claim requires deliberate or reckless false statements or omissions that were material to probable cause. The court found that the complaint did not allege facts showing that Estrada or Duran deliberately or recklessly made false statements or omissions in reports to the juvenile court.

Disposition

The court ordered that the motion to dismiss was granted in part and denied in part. Claims 6 and 7 against Estrada and Duran were dismissed with leave to amend. Any amended complaint had to be filed by November 15, 2019. Amendment was limited to the deficiencies identified in the order, and the plaintiffs could not add parties or claims without the court’s prior express permission.