Geraci v. Hamilton

District of Columbia Court of Appeals·Decided February 5, 2026·No. 22-CV-0749·Published

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS No. 22-CV-0749

DONNA M. GERACI, et al., APPELLANTS, V.

IAN HAMILTON, et al., APPELLEES.

Appeal from the Superior Court of the District of Columbia (2020-CA-001915-M)

(Hon. Yvonne Williams, Trial Judge)

(Argued October 12, 2023 Decided February 5, 2026)

Matthew W. Lee, with whom Dov M. Szego was on the brief, for appellants.

Christopher J. Gowen for appellees.

Before BECKWITH and EASTERLY, Associate Judges, and RUIZ, * Senior Judge.

RUIZ, Senior Judge: In the District of Columbia, mandatory reporters of suspected child abuse have statutory “immunity from liability, civil or criminal,”

*

Associate Judge AliKhan was originally assigned to this case. Following Judge AliKhan’s appointment to the United States District Court for the District of Columbia, effective December 12, 2023, Senior Judge Ruiz has been assigned to take her place on the panel.

D.C. Code § 4-1321.04, when making a report in good faith of suspected child abuse pursuant to the mandatory reporting provisions of D.C. Code §§ 4-1321.01 to -1321.08. Before us is an interlocutory appeal from the Superior Court’s denial of a summary judgment motion, in which a mandatory reporter sought dismissal of a claim on summary judgment on the basis of her immunity under the statute. This appeal presents two questions of first impression about that immunity: (1) whether this court has jurisdiction to review the Superior Court’s denial of the statutory immunity on an interlocutory basis under the collateral order doctrine; and (2) if so, the legal standard for rebutting the statutory presumption of good faith (and whether the evidence presented was sufficient to withstand summary judgment). Without minimizing the importance of the immunity provision, we conclude that because the statute confers immunity from liability, as distinct from immunity from suit, denial of the statutory immunity does not satisfy the “effectively unreviewable on appeal” prerequisite for interlocutory appellate review under the collateral order doctrine. As we must dismiss the appeal for lack of jurisdiction, we do not address appellants’ claim of immunity on the merits, and we remand the case with instructions that the trial court continue with the proceedings.

I. Background

A. The Mandatory Reporting Statute Congress first enacted a mandatory reporting statute for the District of Columbia in 1966, Pub. L. No. 89-775, 80 Stat. 1354 (1966), and the D.C. Council amended it with the Prevention of Child Abuse and Neglect Act of 1977, D.C. Law 2-22, 24 D.C. Reg. 3341 (1977). 1 Pursuant to D.C. Code § 4-1321.02, certain professionals designated as “mandatory reporters” are required to make a report to the Child and Family Services Agency (CFSA) or to the Metropolitan Police Department “if they know or have reasonable cause to believe” that a child they know in their professional capacity has been or is in immediate danger of being, among other things, the victim of sexual abuse. D.C. Code § 4-1321.02(b)(1)(C).

The purpose of the statute is, inter alia, “to require a report of a suspected neglected child in order to identify neglected children.” D.C. Code § 4-1321.01.

1 All fifty states have some version of a mandatory reporting statute, enacted during the 1960s as part of a national movement towards protecting children. State v. Strauch, 345 P.3d 317, 322 (N.M. 2015) (reviewing secondary sources). This movement was spurred by a report issued in 1963 by the federal Children’s Bureau, which appended a model statute providing for mandatory reporting and immunity from liability. CHILDREN’S BUREAU, U.S. DEP’T OF HEALTH, EDUC., AND WELFARE, THE ABUSED CHILD—PRINCIPLES AND SUGGESTED LANGUAGE FOR LEGISLATION ON REPORTING OF THE PHYSICALLY ABUSED CHILD (1963). Congress later passed the Child Abuse Prevention and Treatment Act in 1974, requiring mandatory reporting laws as a condition for receiving certain federal grants. 42 U.S.C.A. § 5106a(b)(2)(B).

Consistent with this stated purpose, it incentivizes reporting in two ways. On the one hand, willful failure to make such a report is criminally punishable with a fine, 180 days’ imprisonment, or both. Id. § 4-1321.07. On the other hand, mandatory reporters are shielded from liability, both civil and criminal, for reports made in good faith, even if those reports ultimately turn out to be mistaken. See id. § 4-1321.04. At issue here is that immunity provision, which provides in full that:

Any person, hospital, or institution participating in good faith in the making of a report pursuant to this subchapter shall have immunity from liability, civil or criminal, that might otherwise be incurred or imposed with respect to the making of the report. Any such participation shall have the same immunity with respect to participation in any judicial proceeding involving the report. In all civil or criminal proceedings concerning the child or resulting from the report good faith shall be presumed unless rebutted.

Id. The text of the current immunity provision is essentially identical to the language enacted by Congress in 1966, see Pub. L. 89-775, § 4, 80 Stat. 1354, 1354 (1966), except that the presumption of good faith was added to the final sentence by the D.C. Council in 1977. Prevention of Child Abuse and Neglect Act, D.C. Law 2-22, § 1- 103(e), 24 D.C. Reg. 3341 (1977). 2

2 The D.C. Council has also enacted a separate statute providing that “[a]ny person who knows, or has reasonable cause to believe, that a child is a victim of sexual abuse shall immediately report such knowledge or belief to the police” or to the CFSA. D.C. Code § 22-3020.52(a). This provision does not alter the special

Two key aspects of the immunity provision bear highlighting for purposes of this case. First, and most importantly, the immunity conferred is “immunity from liability, civil or criminal.” D.C. Code § 4-1321.04. Second, the statute establishes a presumption (albeit a rebuttable one) that reports of suspected abuse are made in good faith. See id.

B. Factual and Procedural Background Appellee, Ian Hamilton, filed this action, on his own behalf and on behalf of his minor child, S.Z.H., against appellants Donna M. Geraci and Creative Ways Therapy alleging (among other things) professional malpractice and intentional infliction of emotional distress. Ms. Geraci is a licensed clinical social worker at Creative Ways Therapy and a mandatory reporter under D.C. Code § 4- 1321.02(a)(17). When S.Z.H. was three years old and a patient at Creative Ways, Ms. Geraci made a report to CFSA regarding possible sexual abuse of S.Z.H. by Mr. Hamilton. For purposes of this appeal, we presume, as the trial court appeared

duty to report imposed on mandatory reporters, id. § 22-3020.52(d) and carries a civil instead of criminal penalty. Id. § 22-3020.54(a). It also includes a substantially similar immunity provision. See id. § 22-3020.55(a). Although, both immunity provisions arguably apply to the report at issue in this case, appellants have relied only on D.C. Code § 4-1321.04, and we, therefore, confine our analysis to that provision.

to, that at least a portion of Mr. Hamilton’s and S.Z.H.’s claims arise from that report and from Ms. Geraci’s subsequent testimony in related proceedings.

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