The liberty interest which parents have in the care, custody, and management of their children is not absolute. The liberty interest in familial relations is limited by the compelling governmental interest in the protection of minor children, particularly in circumstances where the protection is considered necessary as against the parents themselves. Moreover, the right to family integrity clearly does not include a constitutional right to be free from child abuse investigations.
The officials were involved in the investigation of the mother's allegations that the father had sexually abused their daughter. The state court resolved the custody dispute and granted the father extensive unsupervised visitation. The father alleged that the officials had interfered with his Fourteenth Amendment liberty interest in the companionship of his daughter. On interlocutory appeal, the court held that the district court erred in failing to grant the officials' separate motions for summary judgment. In so doing, the court found that the officials were entitled to qualified immunity because their actions did not violate the father's constitutional rights.
Did the officials interfere with the father's Fourteenth Amendment liberty interest in the companionship of his daughter?
The father's liberty interest was limited by the government's interest in the protection of minor children. The father did not have a constitutional right to be free from child abuse investigations. Although the father's parental rights were clearly disrupted, it was not clear that the disruption was caused by the unreasonable or unconstitutional actions of the officials. The record of the investigation did not demonstrate conduct so outrageous that it offended the substantive component of the Due Process Clause.