Flores-Grgas v. The Administration of Children's Services of the City of New…

Background

Karina E. Flores-Grgas and Mike Grgas appeared without lawyers and alleged that their federally protected rights were violated in connection with the removal of their children, identified in the opinion as F.S., G.G., and M.G., from their custody and the children’s later adoption. The complaint alleged that the New York City Administration for Children Services removed F.S. after accusing Flores-Grgas of failing to take prescribed medication and later removed G.G. and M.G. based on similar accusations. The opinion states that F.S. was adopted on February 18, 2018; G.G. on June 4, 2019; and M.G. on October 4, 2019.

Plaintiffs described appeals and other proceedings in New York state courts concerning the custody, termination of parental rights, and adoptions. They asked the federal court to review or overturn the adoption orders, restore custody, and award money damages. The complaint also appeared to raise concerns about conditions in the adoptive home of F.S. and M.G.

Claims and Analysis

Because plaintiffs alleged constitutional violations, the court treated the complaint as asserting claims under 42 U.S.C. § 1983. That statute requires a plaintiff to allege both a violation of a federal right and conduct by a person acting under state authority.

Claims against the New York City agency and the City

The court dismissed the claims against the New York City Administration for Children Services because a New York City agency is not a suable entity. The court treated the allegations as also asserting claims against the City of New York, which can be sued, but dismissed those claims for failure to state a claim. To impose liability on a municipality under § 1983, a plaintiff must allege that a municipal policy, custom, or practice caused the constitutional violation. The court found that plaintiffs alleged no facts showing such a policy, custom, or practice.

Claims against Catholic Guardian Services

The court described Catholic Guardian Services as a private organization. A private organization can be treated as acting under state authority only in limited circumstances, such as when the state coerces or controls its conduct, when the organization acts jointly with the state, or when the state delegates a public function to it. The court found that plaintiffs did not allege facts showing that Catholic Guardian Services acted under state authority. It also found that plaintiffs did not allege any facts implicating Catholic Guardian Services in the events underlying their claims. The court therefore dismissed the claims against that organization for failure to state a claim.

State-court judgments and domestic-relations issues

The court ruled that, even if plaintiffs had sued an appropriate defendant, their claims were barred by the Rooker-Feldman doctrine and the domestic-relations abstention doctrine. Rooker-Feldman prevents a federal district court from functioning as an appeal court for final state-court judgments. The court found that plaintiffs lost in state court, complained of injuries caused by the state-court judgments, asked the federal court to review and reject those judgments, and filed this federal case afterward.

The court also held that it had to abstain, meaning refrain from exercising its authority, over plaintiffs’ requests to overturn or interfere with Family Court custody and adoption orders. The court stated that plaintiffs’ allegations did not suggest they had been denied a full and fair hearing in state court.

State-law claims and amendment

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over any state-law claims plaintiffs might have been asserting. Supplemental jurisdiction is the federal court’s discretionary authority to hear related state-law claims in the same case.

The court denied leave to amend because it found that the defects in the complaint could not be cured by amendment. The opinion does not state that the dismissal was with or without prejudice.

Disposition

The court dismissed plaintiffs’ claims for failure to state a claim and as barred by the Rooker-Feldman doctrine and the domestic-relations abstention doctrine. It declined to exercise supplemental jurisdiction over any possible state-law claims, denied leave to amend, and certified that any appeal would not be taken in good faith; it therefore denied plaintiffs fee-free status for purposes of an appeal.