Williams v. County Of Monterey

Background

Monia Williams sued on behalf of herself and as guardian ad litem for her minor children, L.S. and Q.S. The defendants included Monterey County, the City of Salinas, social workers, and police officers involved in the children’s removal based on suspected abuse. The children were removed from Williams’s custody and remained outside her home for approximately three months. The juvenile proceedings were later dismissed after a contested trial.

The amended complaint alleged that officials conducted inadequate and misleading investigations. Among other allegations, Williams claimed that social workers and police officers misunderstood or misrepresented the children’s statements, that officials decided to remove the children despite inconsistencies in those statements, and that officials presented false or incomplete information during the juvenile court proceedings.

Estrada and Duran were Santa Cruz County social workers assigned to conduct an independent investigation. Duran supervised Estrada. The amended complaint alleged that Estrada was given more than twelve body-camera videos but watched only one after Duran directed him to stop. It also alleged that Estrada knew the children could not be qualified during their interviews but intentionally left that information out of his report to the juvenile court.

Claims and arguments

The motion concerned Claim 6, brought under 42 U.S.C. § 1983 for violation of substantive due process rights to family association, and Claim 7, a state-law claim for intentional infliction of emotional distress. The constitutional claim alleged that Estrada and Duran submitted fraudulent information to the juvenile court, causing the family’s continued separation after the initial removal.

Estrada and Duran argued that the amended complaint still did not allege a constitutional violation and that they were protected by qualified immunity. Qualified immunity can protect government officials from damages when their conduct did not violate a clearly established constitutional right. They also argued that the emotional-distress claim was inadequately pleaded and that California immunity laws protected them from that claim.

Court’s analysis

Applying the standard for a motion to dismiss for failure to state a claim, the court accepted the complaint’s factual allegations as true and drew reasonable inferences in Williams’s favor. The court explained that a parent’s right to companionship with a child is protected by substantive due process and that official conduct must be sufficiently conscience-shocking to support such a claim.

The court found the new allegations significant. It held that the allegations that Estrada and Duran deliberately avoided potentially exculpatory evidence and that Estrada omitted known information about the children’s inability to be qualified were sufficient, at the pleading stage, to allege deception in presenting evidence during a protective-custody proceeding. The court therefore concluded that the amended complaint adequately stated Claim 6 and that the allegations could place the conduct outside qualified immunity. The court denied the motion to dismiss Claim 6, without prejudice to a later motion for summary judgment based on qualified immunity.

For Claim 7, the court applied California’s elements for intentional infliction of emotional distress: intentional or reckless conduct, severe emotional distress, and causation by outrageous conduct. The court found the allegations that Estrada and Duran participated in a plan to make the abuse and failure-to-protect allegations “stick,” and that their conduct caused the children’s continued separation and severe emotional distress, sufficient to state the claim.

The court also considered California Government Code sections 820.2 and 821.6, which can provide immunity for certain discretionary, investigative, and prosecutorial decisions. It noted that section 820.21 limits those immunities for certain conduct committed with malice, including fraud. The court found that the amended allegations could bring Estrada and Duran’s conduct within that exception. It denied the motion to dismiss Claim 7, without prejudice to a later motion for summary judgment based on state-law immunities.

Disposition

The court denied the motion to dismiss. Estrada and Duran were ordered to file answers by February 12, 2020.