Bush v. Derico (MAG2)

CourtDistrict Court, M.D. Alabama
DecidedDecember 6, 2024
Docket2:23-cv-00673
StatusUnknown

This text of Bush v. Derico (MAG2) (Bush v. Derico (MAG2)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bush v. Derico (MAG2), (M.D. Ala. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

ADAM BUSH, et al., ) ) Plaintiffs, ) ) v. ) CIVIL CASE NO. 2:23-cv-673-ECM ) [WO] ALABAMA DEPARTMENT OF ) HUMAN RESOURCES, et al., ) ) Defendants. )

MEMORANDUM OPINION and ORDER I. INTRODUCTION On August 2, 2024, the Magistrate Judge entered a Recommendation in this case. (Doc. 45). To date, no objections to the Recommendation have been filed. Upon an independent review of the file and upon consideration of the Recommendation, the Court concludes the Recommendation is due to be adopted in part with modifications and rejected in part. II. BACKGROUND Plaintiffs Adam Bush (“Bush”); Delsea Creel (“Creel”); L.C., an infant minor, by and through her father and mother as her next best friend (“L.C.”); and H.E., a minor, by and through his mother as his next best friend (“H.E.”) (collectively, “Plaintiffs”), bring this action against Defendants Alabama Department of Human Resources (“Alabama DHR”), Nancy Buckner (“Buckner”), Dan Williams (“Williams”), Estella Derico (“Derico”), Supervisor Presley (“Presley”), the Health Care Authority for Baptist Health, d/b/a Baptist Medical Center East (“Baptist”), an unknown nurse at Baptist Medical Center East (“Unknown Nurse”), and an unknown employee of Baptist Medical Center East

(“Unknown Employee”) (collectively, “Defendants”) for violations of federal and state law surrounding the removal of L.C. from her parents’ custody shortly after her birth. Count I is brought against all Defendants pursuant to 42 U.S.C. § 1983 and alleges that Alabama DHR’s policies and procedures are unconstitutional and that the Defendants violated the Plaintiffs’ Fourth, Fifth, Sixth, and Fourteenth Amendment rights. Count II alleges that Alabama DHR, Buckner, Williams, Derico, and Presley failed to follow

Alabama DHR’s policies and procedures in violation of Plaintiffs’ Fourth, Fifth, Sixth, and Fourteenth Amendment rights. Count III alleges wantonness and negligence against all Defendants. Count IV alleges intentional infliction of emotional distress against all Defendants. Count V alleges negligent supervision against Alabama DHR, Buckner, and Williams. Count VI alleges fraudulent misrepresentation against Alabama DHR,

Williams, Derico, and Presley. Finally, Count VII alleges fraudulent misrepresentation against Baptist and Unknown Employee. The Magistrate Judge recommends that Baptist’s motion to dismiss (doc. 10) be granted, Williams’ motion to dismiss (doc. 13) be granted, Alabama DHR’s motion to dismiss (doc. 14) be granted, Derico’s motion to dismiss (doc. 36) be granted in part and

denied in part, and that all claims against Buckner, Presley, Unknown Nurse, and Unknown Employee be dismissed with prejudice.

2 III. DISCUSSION The Court has carefully reviewed the Recommendation and the entire record.

Although the Court disagrees with, and declines to adopt, some of the Recommendation’s analysis, the Court ultimately concludes that the Recommendation is due to be adopted in part as modified herein and rejected in part. A. Claims against Baptist The Magistrate Judge recommends that Baptist’s motion to dismiss be granted and all claims against it be dismissed with prejudice. (Doc. 45 at 26–31). Regarding the

constitutional claims brought pursuant to § 1983, the Magistrate Judge found that “Plaintiffs have failed to allege that Baptist was a state actor or an agent of the state when the unknown nurse tested L.C.’s meconium or the unknown administrative employee failed to obtain appropriate paperwork regarding L.C.’s custody.” (Id. at 27). The Court does not disturb this finding but emphasizes, as the Magistrate Judge does later in her

Recommendation (id. at 46–47), that even if Plaintiffs properly alleged that Baptist was a state actor or agent, the § 1983 claims against it are due to be dismissed because the Plaintiffs have not pled sufficient facts giving rise to supervisory liability. B. Claims against Alabama DHR The Magistrate Judge recommends that Alabama DHR’s motion to dismiss be

granted and all claims against it be dismissed with prejudice because suit against Alabama DHR is barred by the Eleventh Amendment. (Doc. 45 at 23–26). The Court does not disturb this finding but adds that any claims against Alabama DHR pursuant to state law 3 are also barred by Article I, § 14 of the Alabama Constitution, because Alabama DHR is a state agency and “[s]tate officers and employees, in their official capacities and

individually, are [] absolutely immune from suit when the action is, in effect, one against the state.” Phillips v. Thomas, 555 So. 2d 81, 83 (Ala. 1989). C. Claims against Derico The Magistrate Judge recommends that Derico’s motion to dismiss be denied as to Bush and Creel’s Fourteenth Amendment, outrage, and fraudulent misrepresentation claims, but granted on all remaining claims. (Doc. 45 at 31–43, 48). As to the § 1983

claims, the Magistrate Judge found that Derico is not, at this stage, entitled to qualified immunity, and that the Fourteenth Amendment claims against her should proceed. The Court agrees with that finding. The Magistrate Judge also found that state agent immunity applies to the negligence and wantonness claims and, accordingly, recommended that those claims be dismissed.

(Doc. 45 at 39–40). The Magistrate Judge correctly acknowledges the second exception to state agent immunity under Ex parte Cranman: “when the [s]tate agent acts willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law.” 792 So. 2d 392, 405 (Ala. 2000). Relying on this as the sole exception to state agent immunity, the Magistrate Judge concludes that Plaintiffs’

negligence and wantonness claims are due to be dismissed because, by definition, these claims allege conduct that was not willful, malicious, fraudulent, in bad faith, beyond Derico’s authority, or under a mistaken interpretation of law. 4 The Magistrate Judge fails, however, to analyze these claims under Cranman’s first exception: “when the Constitution or laws of the United States, or the Constitution of this

State, or laws, rules, or regulations of this State enacted or promulgated for the purpose of regulating the activities of a governmental agency require otherwise.” Id. This exception to state agent immunity largely tracks the qualified immunity analysis. Cantu v. City of Dothan, 974 F.3d 1217, 1236 (11th Cir. 2020). To that effect, “the same facts that establish an officer is not entitled to qualified immunity ‘also establish that [she] is not entitled’ to state agent immunity.” Id. (quoting Hunter v. Leeds, 941 F.3d 1265, 1284 (11th Cir. 2019)).

State officials are not entitled to state agent immunity if their conduct, as pleaded, plausibly violates the United States Constitution. See, e.g., Taylor v. Hughes, 920 F.3d 729, 734–35 (11th Cir. 2019) (holding that the district court erred in granting summary judgment in favor of state officials based on state agent immunity because the state officials “potentially violated [the plaintiff’s] constitutional rights by being deliberately indifferent to his serious

medical needs”); Foster v. Maloney, 785 F. App’x 810, 818–19 (11th Cir.

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Related

Phillips v. Thomas
555 So. 2d 81 (Supreme Court of Alabama, 1989)
Ex Parte Cranman
792 So. 2d 392 (Supreme Court of Alabama, 2000)
Bonny Edward Taylor v. Henry P. Hughes
920 F.3d 729 (Eleventh Circuit, 2019)
Ronald Hunter, Jr. v. Leeds, City of
941 F.3d 1265 (Eleventh Circuit, 2019)
Christopher Cantu v. City of Dothan, Alabama
974 F.3d 1217 (Eleventh Circuit, 2020)

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