Endy v. County of Los Angeles, No. 19-55663 (9th Cir. 2020)
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The Ninth Circuit affirmed the district court's grant of summary judgment for defendants in an action brought by plaintiff under 42 U.S.C. 1983, alleging that the County and DCFS violated plaintiff's due process and privacy rights by maintaining unfounded child abuse allegations against plaintiff in California's Child Welfare Services Case Management System (CWS/CMS) without providing him notice or a hearing to challenge them.
The panel held that the County has a strong interest in maintaining all reports of suspected child abuse in CWS/CMS—even those that result in "unfounded" dispositions—because doing so helps its child welfare and law enforcement agencies protect children from abuse and neglect. In this case, plaintiff failed to raise a triable issue of material fact that the records of his "unfounded" allegations in CWS/CMS caused him reputational harm, or that they are used by the County to alter or extinguish his rights to employment, child placement, or child visitation. Therefore, plaintiff failed to show that his inclusion in CWS/CMS implicates his liberty interests so as to require procedural due process. Furthermore, plaintiff has not shown that the County publicly disseminates or misuses his information in a manner that would violate his constitutional right to privacy.
Court Description: Civil Rights. The panel affirmed the district court’s summary judgment in favor of defendants in an action brought pursuant to 42 U.S.C. § 1983 alleging that the County of Los Angeles and its Department of Children and Family Services violated plaintiff’s due process and privacy rights by maintaining unfounded child abuse allegations against plaintiff in the California’s Child Welfare Services Case Management System without providing him notice or a hearing to challenge them. The panel held that the County has a strong interest in maintaining all reports of suspected child abuse in the Child Welfare Services Case Management System (CWS/CMS)— even those that result in “unfounded” dispositions—because doing so helps its child welfare and law enforcement agencies protect children from abuse and neglect. Here, plaintiff failed to raise a triable issue of material fact that the records of his “unfounded” allegations in CWS/CMS caused him reputational harm, or that they were used by the County to alter or extinguish his rights to employment, child placement, or child visitation. The record indicated that the County considers only “substantiated” and “inconclusive” allegations to be risk factors for child placement, but not “unfounded” ones such as plaintiff’s. Accordingly, plaintiff failed to show that his inclusion in CWS/CMS implicated his liberty interests so as to require procedural due process. ENDY V. COUNTY OF LOS ANGELES 3 The panel also held that plaintiff had not shown that the County publicly disseminates or misuses his information in a manner that would violate his constitutional right to privacy.
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