Vaughn v. Ruoff - 253 F.3d 1124 (8th Cir. 2001)

Rule:

Qualified immunity analysis initially asks the following two questions: (1) was there a deprivation of a constitutional right, and, if so, (2) was the right clearly established at the time of the deprivation? If either question is answered in the negative, the public official is entitled to qualified immunity. If both questions are answered in the affirmative, a public official can avoid a denial of qualified immunity only if she meets her burden of establishing undisputed and material predicate facts which demonstrate that her actions were reasonable under the circumstances. If the material predicate facts are undisputed, the reasonableness inquiry is a question of law. If there is a genuine dispute over material predicate facts, a public official cannot obtain summary judgment.

Facts:

Plaintiff Margaret Vaughn was diagnosed as mentally handicapped and had a daughter born with health problems that required ongoing medical care. The Missouri Division of Family Services (" MDFS") took custody of the daughter, finding that plaintiffs failed to maintain a sanitary home and could not demonstrate an ability to rear her properly. Despite birth control, plaintiff became pregnant again. The state again took custody of the second child for the same reasons. The same day as, but after, the second child's birth, the social worker told plaintiffs that if either would get sterilized, their chances of getting the children back would be greater. Plaintiff agreed to sterilization. About three months later, the state informed plaintiffs that it would recommend termination of their parental rights. Plaintiffs brought due process claims, and the social worker argued that she was entitled to qualified immunity. The district court denied the social worker’s motion for summary judgment as to the federal and state due process claims. The social worker appealed.

Issue:

1. Did the plaintiff possess a protected liberty interest under the Fourteenth Amendment?
2. Did the social worker’s conduct violate the plaintiff’s due process rights?

Answer:

1) Yes. 2) Yes.

Conclusion:

The Court found that plaintiff had a protected liberty interest under the Fourteenth Amendment, since personal decision relating to procreation or contraception was a protected liberty interest. According to the Court, all persons, including the mentally handicapped, possessed this liberty interest. Anent the second issue, the Court held that the social worker's conduct violated plaintiff’s due process rights. Before the State may deprive an individual of a protected liberty interest, the Due Process Clause required the State to provide certain procedural protections, i.e., notice and opportunity for hearing appropriate to the nature of the case. In this case, the Court noted that the social worker coerced the plaintiff into submitting to sterilization, and this implicated due process concerns. It was undisputed that plaintiff was not given any procedural protections before the sterilization occurred. The unconstitutionality of the social worker's alleged conduct was clearly established at the time it occurred.