Engler v. Arnold, No. 16-4201 (6th Cir. 2017)
Annotate this CaseT.F., a child, was abused and killed by his stepfather. In a complaint under 42 U.S.C. 1983, T.F.’s estate alleged that Arnold, the Interim Executive Director of the Mahoning County Children’s Services Board, received reports about the abuse, but did not investigate or cooperate with law enforcement, as required by statute, and that “Arnold’s inaction with regard to notification that T.F. was an abused child increased T.F.’s susceptibility to future violence and abuse.” The Sixth Circuit affirmed dismissal, noting that it had no information about the events that led to T.F.’s death other than that T.F.’s stepfather caused his death, and that T.F.’s mother and stepfather were incarcerated following a police investigation. The complaint failed to explain the duration or extent of the abuse by T.F.’s stepfather, describing only one instance, two days before T.F.’s death, when “T.F. was admitted to the hospital suffering from, among other things, frost bite and serious bruises.” T.F.’s stepfather apparently forced him to stand outside at night without proper protective clothing. The complaint did not explain when abuse allegations were brought to Arnold’s attention but stated only that Arnold “concluded that T.F.’s injuries . . . were accidental and refused to report or investigate those allegations of abuse.”
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