Nicole Maddoxv.Babette Stephens
Nicole Maddox sued Georgia DFCS social worker Babette Stephens under 42 U.S.C. § 1983 after a medically fragile child was discharged from a hospital to the child’s father and paternal grandmother. Maddox alleged that Stephens helped prepare a safety plan and told her she could not remove the child from the grandmother’s care, temporarily interfering with Maddox’s custodial rights. The district court denied Stephens summary judgment on Maddox’s substantive due process claim, and Stephens brought an interlocutory appeal. The Eleventh Circuit reversed that ruling and held that Stephens was entitled to qualified immunity. The court assumed, without deciding, that Stephens’s actions could implicate Maddox’s custodial liberty interest and that the state’s procedures may have been mishandled. But substantive due process requires conduct so arbitrary or conscience-shocking that a reasonable official would have known it was unconstitutional. The record showed that the grandmother was the only family member trained to provide the child’s intensive medical care, while Maddox had not completed the necessary training before discharge. In that unusual setting, the law did not clearly establish that Stephens’s safety-plan conduct violated substantive due process. The panel expressly declined to decide Maddox’s procedural due process claim. It reversed the denial of qualified immunity and remanded.
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