Webb v. Smith, No. 18-2541 (8th Cir. 2019)
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Plaintiffs filed suit on behalf of themselves and their children against the social workers involved in their cases and two of their DHS supervisors, alleging violations of their constitutional rights. The Eighth Circuit held that plaintiffs had standing to seek damages, to the extent they did so, against the individual defendants where plaintiffs' injuries were fairly traceable to defendants. However, plaintiffs lacked standing to obtain declaratory and injunctive relief, which they sought as remedies for their facial attack on the constitutionality of the relevant statutes, because the injury was too speculative to form the basis for the relief sought. The court upheld the district court's dismissal of plaintiffs' facial challenge to the relevant statutes, but remanded with instructions to dismiss the claim without prejudice.
On the merits, the court held that plaintiffs' damages claims against social workers for failure to receive prompt post-deprivation hearings failed, because the social workers did not contribute to any subsequent delays, considering they lacked the authority to file ex parte petitions or to schedule hearings on state-court dockets. Furthermore, the court could not say that a policy or custom the supervisors created or applied, or their alleged failure to train or supervise, caused plaintiffs' harm. However, the court held that the district court erred in applying the Rooker-Feldman doctrine to plaintiffs' claim that the social workers used ex parte proceedings containing knowingly false allegations, because the state court never issued any judgments in the case. Accordingly, the court remanded for the district court to consider the claims on the merits.
Court Description: Arnold, Author, with Gruender and Stras, Circuit Judges] Civil case - Civil rights. Plaintiffs had standing to seek damages against the defendant social workers and their supervisors for initiating court proceedings to remove the plaintiffs' children from their custody as any injury plaintiffs suffered was fairly traceable to defendants' actions; plaintiffs lacked standing to obtain declaratory and injunctive relief, which they sought as remedies for their facial attack on the relevant Arkansas statutes, as any injury they asserted was too speculative to form the basis for the relief sought; plaintiffs dismissal of the plaintiffs' facial challenge is affirmed, but on remand, the district court should dismiss the claim without prejudice; the damages claims against the social worker defendants for untimely post-deprivation hearings fail as the defendants did not contribute to the delay as they timely engaged the judicial machinery and lacked authority to file ex parte petitions or to schedule hearings on state court dockets; same claims against the social workers' supervisors fail as the social workers did not cause plaintiffs' harm and the court could not say a policy or custom the supervisors created or applied, or their alleged failure to train or supervise the social workers, did either; the district court erred in applying the Rooker-Feldman doctrine to bar plaintiffs' claim that the social workers violated their rights by seizing their children using ex parte proceedings containing knowingly false allegations, as the state court never issued any judgments in the cases; on remand, the district court should consider whether the claims have any merit.
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