Feng v. County of Santa Clara

Background

Karena Feng, proceeding without a lawyer, filed one of five lawsuits based on the same underlying events involving the removal of her children from her custody. The court had already dismissed Feng’s amended complaint against a psychiatrist, several social workers, a state-court judge, a court-appointed attorney, the City and County of San Francisco, and one San Francisco social worker. The remaining defendants were Santa Clara County and Santa Clara social workers Mayra Alvarez and Brian Hawkinson.

Feng alleged that a psychiatrist threatened to involve child-protection authorities, that she was involuntarily placed in a psychiatric facility, and that Alvarez and Hawkinson made false or altered statements in connection with petitions concerning her children. She also alleged that the state-court proceedings resulted in the children being placed in foster homes and that social workers later interfered with visitation, therapy, evaluations, and reunification. Her amended complaint asserted claims under 42 U.S.C. § 1983, the Fourteenth Amendment, and the Racketeer Influenced and Corrupt Organizations Act, commonly called RICO.

Feng did not oppose the Santa Clara defendants’ motion to dismiss. The court decided the motion without oral argument.

Analysis

The court applied the rule that federal district courts generally cannot act as appeals courts reviewing state-court judgments. It held that Feng’s claims were inseparably connected to the state-court custody proceedings because she sought to disturb the custody decision and have her children returned. The court therefore ruled that this doctrine barred her claims against the Santa Clara defendants. Because of that ruling, it did not decide the defendants’ additional arguments that Feng failed to adequately allege Alvarez’s participation in the removal or Hawkinson’s fraudulent conduct.

The court also ruled that Feng did not adequately plead municipal liability against Santa Clara County. To state such a claim under § 1983, a plaintiff must allege that a government entity had a policy or custom that caused a constitutional violation. The court found that Feng at most alleged that the County failed to investigate the psychiatrist’s alleged misconduct, and that she did not plead an underlying constitutional violation or a qualifying County policy.

Finally, the court ruled that Feng did not state a valid civil RICO claim because she did not allege an injury to her business or property resulting in a concrete financial loss.

Disposition

The court granted the pending motion to dismiss. It dismissed the amended complaint with prejudice because amendment would not cure the deficiencies. Judge Laurel Beeler stated that the order disposed of ECF No. 82.