Justia Civil Rights Opinion Summaries

A social worker employed by the Department was the primary case worker for plaintiffâs son, who was removed from his motherâs custody by the Department. After boy was adjudicated neglected by the juvenile court, custody was granted to his maternal great aunt and uncle. Plaintiff, who wished to take custody, claimed that the social worker misrepresented his desire and ability to parent and impeded his ability to participate in custody proceedings. The district court denied the social worker's motion for summary judgment on claims under 42 U.S.C. 1983. The Sixth Circuit reversed, holding that the social worker is absolutely immune from suit for her participation in juvenile court proceedings, regardless of whether she conducted an inadequate investigation or knowingly made false statements. Because the social worker's conduct neither caused any deprivation of the plaintiff's interest in family integrity, nor interfered with the process, qualified immunity barred remaining claims. The juvenile court was responsible for the "deprivation" and the plaintiff had notice and an opportunity to be heard.