Angela Miller, et al. v. Richland County Children Services, et al.

CourtDistrict Court, N.D. Ohio
DecidedNovember 5, 2025
Docket1:25-cv-01675
StatusUnknown

This text of Angela Miller, et al. v. Richland County Children Services, et al. (Angela Miller, et al. v. Richland County Children Services, et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angela Miller, et al. v. Richland County Children Services, et al., (N.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO

Angela Miller, et al., Case No. 1:25cv01675

Plaintiffs, -vs- JUDGE PAMELA A. BARKER

MEMORANDUM OPINION Richland County Children Services, et al., AND ORDER

Defendants.

Pro se plaintiffs Angela Miller and Jason L. Miller, Sr. filed a civil rights action under 42 U.S.C. § 1983 against the Richland County Children Services, CASA of Richland County (presumably Court Appointed Special Advocates), ViaQuest, Magistrate Karen Cannon, Mansfield Police Department, Lexington Police Department, and New Hope Behavioral Health, concerning the custody of their minor child.1 (Doc. No. 1). On September 30, 2025, Plaintiffs filed a motion to amend the complaint. (Doc. No. 3). The motion included a request to correct a clerical error and to add additional claims as well as a new defendant, Lexington High School. The Court grants Plaintiffs’ motion and considers this document as part of the operative complaint. Plaintiffs also filed an application to proceed in forma pauperis (Doc. No. 2). The Court grants the application. I. Background This complaint stems from a Richland County Juvenile Court case and the removal of Plaintiffs’ child from their home. According to the complaint, Children Services visited Plaintiffs’

1 Although the complaint references two children, the allegations appear to pertain only to Plaintiffs’ younger son. (See Doc. No. 1-2 at 1). home “following a previously failed visit” and “accused [Plaintiffs] of neglect and sexual misconduct.” (Doc. No. 1-2 at 1). Plaintiffs signed a safety plan “under immense pressure and fearing arrest,” their children were removed from the home, and the plaintiffs were denied contact with the children. Following an investigation, Plaintiffs’ older son was permanently placed with a

family member and the younger son, who appears to be the subject of this complaint, was placed in an Intermediate Care Facility (“ICF”), which was later ViaQuest. Court-ordered visitation changed from three overnights per week to one overnight visit. Thereafter, Children Services filed a motion for temporary custody, which the court granted. (Id.). Plaintiffs state that Children Services and the local school district conducted an IEP without notifying Plaintiffs and they determined that Plaintiffs’ minor child would not be permitted to attend the technical school program he selected, “based solely on his disability.” (Id.). Plaintiffs claim that their child was removed from their home without a warrant or exigent circumstances, Children Services acted in concert with local law enforcement and other agencies or officials to remove their child despite having no evidence of immediate danger, the defendants

failed to provide Plaintiffs with notice or a hearing prior to depriving them of their parental rights, Plaintiffs were denied access to CASA reports (including notes provided by ViaQuest), Lexington High School ignored the child’s IEP and denied Plaintiffs access to their son’s records, and Magistrate Cannon denied Plaintiff Angela Miller the right to cross-examine her husband, Jason L. Miller, Sr., and denied her the right to present evidence. (Doc. Nos. 1, 3). Plaintiffs allege that this conduct constitutes a violation of the First, Fourth, Eighth, and Fourteenth Amendments. Plaintiffs additionally allege that Defendants violated the Americans with Disabilities Act (“ADA”) by excluding their son from the educational program of his choice based strictly on his disability, without accommodations or parental involvement. (Doc. Nos. 1, 1-2 at 2). Plaintiffs request the following relief: return custody of their child; an order compelling CASA to provide to Plaintiffs all documents relating to their case; a permanent restraining order against CASA and Children Services to prevent further harassment or retaliation against Plaintiffs’ family; all state actors “be held accountable, including criminal penalties”; all charges against

Plaintiffs be dismissed; and monetary relief. (Doc. Nos. 1, 1-2). II. Standard of Review Pro se pleadings are liberally construed. Boag v. MacDougall, 454 U.S. 364, 365, 102 S. Ct. 700, 70 L. Ed. 2d 551 (1982) (per curiam); Haines v. Kerner, 404 U.S. 519, 520, 92 S. Ct. 594, 30 L. Ed. 2d 652 (1972). The Court, however, is required to dismiss an in forma pauperis action under 28 U.S.C. §1915(e) if it fails to state a claim upon which relief can be granted, or if it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319, 109 S. Ct. 1827, 104 L. Ed. 2d 338 (1989); Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990); Sistrunk v. City of Strongsville, 99 F.3d 194, 197 (6th Cir. 1996). A claim lacks an arguable basis in law or fact when it is premised on an indisputably meritless legal theory or when the factual contentions are clearly baseless.

Neitzke, 490 U.S. at 327. A cause of action fails to state a claim upon which relief may be granted when it lacks “plausibility in the Complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007). A pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677-78, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009). The factual allegations in the pleading must be sufficient to raise the right to relief above the speculative level on the assumption that all the allegations in the complaint are true. Twombly, 550 U.S. at 555. The plaintiff is not required to include detailed factual allegations but must provide more than “an unadorned, the-Defendant-unlawfully-harmed- me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id. In reviewing a complaint, the Court must construe the pleading in the light most favorable to the plaintiff. Bibbo v. Dean Witter Reynolds, Inc., 151 F.3d 559, 561 (6th Cir.1998).

III. Law and Analysis A. The ADA Claim Plaintiff appears to claim that the defendants violated their minor child’s rights under the Americans with Disabilities Act when they excluded their child from certain educational programs “based on his disability.” They also allege the defendants failed to provide their child accommodations. (See Doc. No. 1-2 at 2). Non-attorney parents, however, cannot appear pro se on behalf of their minor child in lawsuits in federal court. A party may plead and conduct his or her case in person or through a licensed attorney. See 28 U.S.C. § 1654; Eagle Associates v. Bank of Montreal, 926 F.2d 1305, 1308 (2d Cir. 1991). The statute, however, “does not permit plaintiffs to appear pro se where interests other than their own

are at stake.” Shepherd v. Wellman, 313 F.3d 963, 970 (6th Cir. 2002) (citation omitted). This rule “‘protects the rights of those before the court by preventing an ill-equipped layperson from squandering the rights of the party he purports to represent.’” Bass v. Leatherwood, 788 F.3d 228, 230 (6th Cir. 2015) (quoting Zanecki v.

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Angela Miller, et al. v. Richland County Children Services, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/angela-miller-et-al-v-richland-county-children-services-et-al-ohnd-2025.