Humphries v. Cty. of L.A. - 554 F.3d 1170 (9th Cir. 2009)

Rule:

Where a state statute creates both a stigma and a tangible burden on an individual's ability to obtain a right or status recognized by state law, an individual's liberty interest has been violated. A tangible burden exists in this context where a law effectively requires agencies to check a stigmatizing list and investigate any adverse information prior to conferring a legal right or benefit. A tangible burden also exists where the plaintiff can show that, as a practical matter, the law creates a framework under which agencies reflexively check the stigmatizing listing—whether by internal regulation or custom—prior to conferring a legal right or benefit.

Facts:

Accused of abuse by a rebellious child, plaintiffs Craig and Wendy Humphries were arrested, and had their other children taken away from them. When a doctor confirmed that the abuse charges could not be true, the state dismissed the criminal case against them. Notwithstanding the findings of California criminal and juvenile courts that the plaintiffs were factually innocent and the charges not true, the plaintiffs were identified as substantiated child abusers and placed on the California's Child Abuse Central Index (CACI). The plaintiffs then initiated the present action in federal district court, seeking relief pursuant to 42 U.S.C.S. § 1983. The plaintiffs alleged that the actions by California officials deprived them of various rights under the United States Constitution. The United States District Court for the Central District of California granted the officials summary judgment. The plaintiffs appealed. 

Issue:

Did the California’s maintenance of the CACI violate the Due Process Clause of Fourteenth Amendment? 

Answer:

Yes.

Conclusion:

The Court held that the California’s maintenance of the CACI violated the Due Process Clause of Fourteenth Amendment. The Court noted that the stigma of being listed in the CACI as substantiated child abusers, plus the various statutory consequences of being listed on the CACI constituted a liberty interest, of which the plaintiffs could not be deprived without process of law. According to the Court, none of the means for correcting erroneous information in the CACI was well designed to do so. Therefore, the lack of any meaningful, guaranteed procedural safeguards before the initial placement on CACI combined with the lack of any effective process for removal from CACI violated the plaintiffs’ due process rights.