DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
182541P.pdf 08/28/2019 Katelyn Webb v. Chelsea Smith
U.S. Court of Appeals Case No: 18-2541
U.S. District Court for the Eastern District of Arkansas - Little Rock
[PUBLISHED] [Arnold, Author, with Gruender and Stras, Circuit Judges]
Civil case - Civil rights. Plaintiffs had standing to seek damages against
the defendant social workers and their supervisors for initiating court
proceedings to remove the plaintiffs' children from their custody as any
injury plaintiffs suffered was fairly traceable to defendants' actions;
plaintiffs lacked standing to obtain declaratory and injunctive relief,
which they sought as remedies for their facial attack on the relevant
Arkansas statutes, as any injury they asserted was too speculative to form
the basis for the relief sought; plaintiffs dismissal of the plaintiffs'
facial challenge is affirmed, but on remand, the district court should
dismiss the claim without prejudice; the damages claims against the social
worker defendants for untimely post-deprivation hearings fail as the
defendants did not contribute to the delay as they timely engaged the
judicial machinery and lacked authority to file ex parte petitions or to
schedule hearings on state court dockets; same claims against the social
workers' supervisors fail as the social workers did not cause plaintiffs'
harm and the court could not say a policy or custom the supervisors
created or applied, or their alleged failure to train or supervise the
social workers, did either; the district court erred in applying the
Rooker-Feldman doctrine to bar plaintiffs' claim that the social workers
violated their rights by seizing their children using ex parte proceedings
containing knowingly false allegations, as the state court never issued
any judgments in the cases; on remand, the district court should consider
whether the claims have any merit.