Manda Roberson v. The Dakota Boys & Girls Ranch, No. 21-3550 (8th Cir. 2022)
Annotate this Case
The North Dakota Department of Corrections and Rehabilitation took full custody of a young girl, A.A.R., from her parents and placed her at the Dakota Boys & Girls Ranch, a private psychiatric facility. After only a few months there, A.A.R. committed suicide. Her parents sued the Ranch and its employees under 42 U.S.C. Section 1983. The district court dismissed the Complaint, concluding that Plaintiffs failed to state a plausible claim that the Defendants were state actors under Section 1983.
The Eighth Circuit reversed and remanded. The court held that when North Dakota took custody of A.A.R., it had a constitutional duty to provide adequate medical care to her. The court explained that Plaintiffs were legally required to comply with DJS’s choices and could not remove her from the Ranch The district court violated the motion-to-dismiss standard when it concluded that the Complaint, read in conjunction with the May 2018 Order, contains “no factual allegations that the only medical care A.A.R. could have received was that provided by the State of North Dakota.” Further, assuming North Dakota’s constitutional obligation to provide A.A.R.’s medical treatment, the Ranch became a state actor. Thus Plaintiffs state a plausible claim against it under Section 1983. The court further explained that Plaintiffs also state a plausible claim against the Ranch’s employees. Defendants do not contest that a finding of state action by the Ranch establishes state action by its employees. Because Plaintiffs plausibly allege the Ranch was a state actor, its employees were too.
Court Description: [Benton, Author, with Gruender and Grasz, Circuit Judges] Civil case - Civil rights. In a case where plaintiffs' minor decedent committed suicide while in the care of the defendant, the district court dismissed plaintiffs' Section 1983 action on the ground defendants were not state actors. The district court erred in dismissing the action. The State of North Dakota, having taken full custody of the child, outsourced its constitutional duty to provide medical care to a child in its custody to defendants, thereby delegating a traditional, exclusive public function to the defendants and making them state actors; the defendants maintained a clear, ongoing relationship with the North Dakota Division of Juvenile Services by providing long-term care to the child on behalf of the Division, thereby assuming the State's constitutional duty to provide the minor with medical care and making them state actors. [ August 01, 2022 ]
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.