Anthony K. v. State

After Plaintiffs’ oldest three children were removed from Plaintiffs' care and eventually reunified with them, Plaintiffs, individually and as guardians and next friends on behalf of their seven minor children, sued the State, the Department of Health and Human Services (DHHS), and several DHHS employees. The case was brought pursuant to 42 U.S.C. 1983. In the complaint, Plaintiffs sought general and special damages for violations of their constitutionally protected rights to familial integrity, due process, and equal protection. The district court dismissed Plaintiffs’ complaint, concluding (1) only the State had been properly served; (2) the State was entitled to sovereign immunity as to Plaintiffs’ section 1983 claims that requested monetary damages; and (3) the State was entitled to summary judgment on Plaintiffs’ remaining causes of action. The Supreme Court affirmed, holding that the district court (1) properly dismissed DHHS and the DHHS employees for lack of proper service of process; (2) correctly determined that sovereign immunity barred Plaintiffs’ claims against the State for monetary damages under section 1983; and (3) erred in not granting the State’s motion to dismiss all of Plaintiffs’ causes of action but achieved the same result by dismissing all remaining causes of action against the State on summary judgment. View "Anthony K. v. State" on Justia Law