G. F. v. PA DHS

CourtCommonwealth Court of Pennsylvania
DecidedApril 21, 2025
Docket366 M.D. 2024
StatusPublished

This text of G. F. v. PA DHS (G. F. v. PA DHS) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
G. F. v. PA DHS, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

G. F., : Petitioner : : v. : No. 366 M.D. 2024 : Pennsylvania Department of : Argued: December 11, 2024 Human Services, : Respondent :

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE STACY WALLACE, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION BY JUDGE McCULLOUGH FILED: Monday, April 21, 2025

On July 25, 2024, G. F. (Petitioner), a certified educator who has been accused of child abuse, initiated this action by filing a Petition for Review in the nature of a complaint against the Pennsylvania Department of Human Services (Department) seeking declaratory and equitable relief in this Court’s original jurisdiction. Before the Court are the parties’ cross-applications for summary relief. The matter concerns the Department’s interpretation and implementation of this Court’s unanimous en banc decision in S.F. v. Pennsylvania Department of Human Services, 298 A.3d 495 (Pa. Cmwlth. 2023), in which we held, as a matter of first impression, that the process afforded by the Child Protective Services Law1 (CPSL) denied a special education teacher and other teachers like her their right to procedural due process prior to being listed in a state registry as perpetrators in indicated reports of child abuse. Because the Department failed to follow the procedures outlined in S.F., we grant Petitioner’s application for summary relief and deny the Department’s application for summary relief. I. Undisputed Facts2 Petitioner is a professional educator employed at a public school in Pennsylvania. At all times relevant, Petitioner has maintained an emergency Pennsylvania teacher permit from the Department of Education. In addition to his employment at a school district, Petitioner had a summer job at a youth shelter. On July 11, 2023, this Court held in S.F. that the process outlined in the CPSL for adjudicating ChildLine and Abuse Registry (ChildLine or ChildLine Registry) reports involving teachers was constitutionally deficient. Nine days later, on July 20, 2023, a report of child abuse naming Petitioner as a perpetrator was made to the Department. The alleged abuse occurred on July 19, 2023, at his employment at the youth shelter. The Department conducted an investigation and determined, on or about September 2, 2023, that there was substantial evidence of the alleged child abuse. On July 7, 2024, the Department issued a document it called a “Special Transmittal,” entitled “S.F. v. Pennsylvania Department of Human Services – Pre- Deprivation Hearings for Individuals with Valid Teaching Certificate.” It was issued to all Children and Families Regional Offices, all County Children and Youth

1 23 Pa. C.S. §§ 6301-6386.

2 The parties have stipulated to all facts necessary to resolve the cross-applications for summary relief.

2 Agencies, the Pennsylvania Children and Youth Administrators Association, and the Department’s Bureau of Hearings and Appeals (BHA). The Special Transmittal states that its purpose is:

[t]o communicate a Commonwealth Court decision from S.F. v. Pennsylvania Department of Human Services involving alleged perpetrators who hold a valid Pennsylvania (PA) teaching certificate, and to provide guidance to investigative agencies regarding the established pre-deprivation process.

(Pet. for Rev., Ex. A, at 1.) The Special Transmittal includes a brief summary of the S.F. case and holding. It further states that the Department’s Office of Children, Youth, and Families (OCYF) partnered with the BHA to develop a “pre-deprivation process to align with the Commonwealth Court decision for ensuring due process.” Id. at 2. Pursuant to the Special Transmittal,

Individuals meeting pre-deprivation eligibility criteria below and being recommended for an indicated status in a Child Protective Services (CPS) report are entitled to a hearing to determine if prima facie evidence exists prior to being placed on the Pennsylvania child abuse registry as indicated. Id. (emphasis added). The “investigative process” into allegations of child abuse involving teachers remains the same as the process outlined in Sections 6334 and 6368 of the CPSL, 23 Pa. C.S. §§ 6334, 6368. Id. at 5. If the investigators find that the allegations in the ChildLine report are substantiated, the Department must notify the alleged perpetrator and BHA within six calendar days that it is requesting a pre-deprivation hearing. Id. at 6. BHA will then schedule a “pre-deprivation hearing” within 15 calendar days and notify the parties. Id. at 6-7.

3 The Special Transmittal speaks of a two-step hearing process: (1) a “pre- deprivation hearing”; and (2) a “full merits hearing.” The Special Transmittal describes the first step as follows:

This pre-deprivation hearing for an indicated recommendation is an abbreviated virtual hearing (using the virtual software approved by the Commonwealth) that gives the opportunity for the investigative agency representative to present their case and for the alleged perpetrator to have an opportunity to respond to the prima facie evidence presented.

***

During the pre-deprivation hearing, the investigative agency representative shall read the abuse allegation(s), dates of alleged abuse and state the evidence that supports that the abuse occurred. The investigative agency shall be prepared to address each allegation that is being recommended to be indicated for the alleged perpetrator.

The alleged perpetrator is entitled to have legal representation at the pre-deprivation hearing. The alleged perpetrator or their legal counsel will be given the opportunity to present information that disputes the investigative agency information and any relevant documents that may refute the factual allegations made by the investigative agency representative. The alleged perpetrator’s legal counsel may speak on behalf of the alleged perpetrator during the pre-deprivation hearing. BHA will have the opportunity to ask questions to either party, as necessary.

The pre-deprivation hearing does not include the presentation of evidence that is not related to the factual allegations presented by the investigative agency witness, and it does not include a determination of whether substantial evidence exists to indicate because that

4 determination is reserved for the full merits hearing. The investigative agency has the burden to present prima facie evidence. Id. at 7-8 (emphasis added). On July 8, 2024, the day after the Special Transmittal was issued, the Department sent notice to Petitioner that it recommended that he be listed as a perpetrator in an indicated report of child abuse on the ChildLine Registry. On July 12, 2024, the Department’s BHA then sent Petitioner a hearing notice setting a telephone hearing for July 30, 2024. The Hearing Notice states that the purpose of the hearing is “to determine if the allegations are sufficient to list the alleged perpetrator in the child abuse registry.” (Pet. for Rev., Ex. C, at 1.) The Hearing Notice further provides in all capitalized letters “THIS IS NOT A FULL HEARING TO DETERMINE WHETHER OR NOT YOU COMMITTED CHILD ABUSE.” Id. (capitalization in original). The Hearing Notice describes the government’s burden “to show that [its] investigation findings, which are assumed to be true for the purposes of this hearing only, establish sufficient evidence that you are a perpetrator of child abuse as defined by the Child Protective Services Law.” Id. (emphasis added). According to the Hearing notice:

At the hearing, the County Agency or Department representative will present an outline of their evidence showing that you belong on the PA child abuse registry. You will not be permitted to put on a full defense.

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Bluebook (online)
G. F. v. PA DHS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/g-f-v-pa-dhs-pacommwct-2025.