G.K., by their next friend, Katherine Cooper et al. v. Christopher Sununu, Governor of New Hampshire et al.

2024 DNH 078
District Court, D. New Hampshire·Decided September 18, 2024·No. 21-cv-4-PB·Published·Cited by 1 cases

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

G.K., by their next friend, Katherine Cooper et al.

v. Case No. 21-cv-4-PB Opinion No. 2024 DNH 078 Christopher Sununu, Governor of New Hampshire et al.

MEMORANDUM AND ORDER

Six adolescents within the custody of the New Hampshire Division of

Children, Youth, and Families (DCYF) filed a putative class action complaint

seeking injunctive and declaratory relief for alleged violations of the

Americans with Disabilities Act (ADA), the Rehabilitation Act, and the

Adoption Assistance and Child Welfare Act (CWA). Since filing the

complaint, five of the six named plaintiffs have exited DCYF custody.

The defendants move to dismiss the five plaintiffs no longer in DCYF

custody from the suit, arguing that their claims are now moot. The

defendants further move to dismiss the remaining plaintiff’s CWA claim for

lack of statutory standing. For the following reasons, the defendants’ motion

is granted in part and denied in part. I. BACKGROUND 1

In January 2021, four adolescent foster children, G.K., C.I., T.L., and

R.K., filed a complaint on behalf of themselves and a putative class of

similarly situated individuals seeking declaratory and injunctive relief for

alleged deficiencies in New Hampshire’s operation of its foster care program. 2

Count I of the plaintiffs’ initial complaint asserted that the defendants are

violating the due process clause of the Fourteenth Amendment by failing to

provide adolescent foster children (that is, foster children between 14 and 17

years of age) with the right to counsel at certain proceedings. Count II

asserted that the defendants are violating the CWA by failing to ensure that

adolescent foster children receive legally adequate case plans. Finally,

Counts III through VI alleged that the defendants are violating the ADA and

the Rehabilitation Act by systematically placing and retaining adolescent

foster children with mental and behavioral disabilities in congregate care

facilities, even where those children could be appropriately placed in

community-based settings. Doc. 1 at 51-57.

1 I focus here on the facts most relevant to the defendants’ motion to dismiss but incorporate the more detailed account of this litigation’s history outlined in my prior orders. See Doc. 303; Doc. 315.

2 The named plaintiffs are each pursuing this action pseudonymously. In an effort to further protect the plaintiffs’ identities, the parties refer to them using gender-neutral pronouns. I follow suit here.

2 The defendants moved to dismiss each of the plaintiffs’ claims under

Federal Rule of Civil Procedure 12(b)(6). I granted the defendants’ motion

with regards to the plaintiffs’ due process claim but declined to dismiss the

remaining claims. As relevant here, I concluded that, although the CWA does

not explicitly provide for a private right of action, it conferred an individual

right to a case plan that could be enforced through a cause of action under 42

U.S.C. § 1983. Doc. 49 at 26, 34.

A few months later, in November 2021, T.L. was returned to their

parent’s custody. Doc. 100-2. Then, in May 2022, C.I. “aged out” of DCYF

custody upon turning 18 years old. Doc. 100. The defendants moved to

dismiss T.L. and C.I. from the suit, arguing that their claims were moot. Doc.

99. While that motion was pending, R.K. was returned to their parent’s

custody, leaving G.K. as the only named plaintiff still within DCYF custody.

Doc. 178-16. I ultimately denied the defendants’ motion to dismiss without

prejudice based on my conclusion that it was unnecessary to decide given

that at least one named plaintiff remained in DCYF custody and could

advance live claims on behalf of the class. Doc. 137 at 12-13.

In March 2023, the plaintiffs moved to certify a class of certain

adolescent foster children with mental health disabilities. Doc. 152. Shortly

after that motion became ripe, the parties agreed to stay the litigation in

order to pursue mediation. Doc. 259. In January 2024, while the stay was still

3 in place, G.K. aged out of DCYF custody. Doc. 265 at 2. The plaintiffs filed a

motion to amend their complaint to add a new named plaintiff still within

DCYF custody, D.M., which I granted. Id.; see also Doc. 315 at 10.

The parties were ultimately unable to reach a settlement agreement,

and mediation came to a close in April 2024. A few weeks later, the plaintiffs

moved to supplement the expert reports they had submitted in support of

their motion for class certification. Doc. 277. I granted the plaintiffs’ motion

but provided the defendants with the opportunity to respond to the plaintiffs’

supplemental reports through additional discovery and briefing. Doc. 303 at

22-23 & n.5. The defendants were given until August 2024 to submit their

supplemental briefing, which made it impossible for me to rule on the

plaintiffs’ motion for class certification before D.M. aged out of DCYF custody

in July 2024. Doc. 287 at 23, 19-20. Consequently, I granted the plaintiffs’

request to amend their complaint to add a sixth named plaintiff, B.D., who

has remained in DCYF custody. Doc. 315 at 13.

The parties have submitted their supplemental briefing, and the

plaintiffs’ motion for class certification is now ripe for resolution. The

defendants have renewed their motion to dismiss those named plaintiffs who

have exited DCYF custody and, further, move to dismiss B.D.’s CWA claim.

II. ANALYSIS

The defendants assert that G.K., C.I., T.L., R.K., and D.M. must be

4 dismissed from the action because their claims for prospective relief are now

moot. 3 The defendants further assert that B.D. lacks statutory standing to

pursue their CWA claim because they do not receive federally-reimbursed

foster care maintenance payments.

The plaintiffs contend that none of their claims are moot under the so-

called inherently transitory exception to mootness. The plaintiffs further

argue that B.D. has standing to advance their CWA claim, even if they do not

receive foster care maintenance payments, because the CWA’s case planning

requirements apply to all foster children.

I begin by considering the defendants’ arguments on statutory standing

before turning to their arguments on mootness.

A. Statutory Standing

“When a plaintiff alleges injury to rights conferred by a statute, two

separate standing-related inquiries pertain: whether the plaintiff has Article

3 The defendants argue that, because these named plaintiffs’ claims are now moot, they lack Article III standing. In doing so, the defendants erroneously conflate standing with mootness. See Friends of the Earth, Inc. v. Laidlaw Env’t Servs. (TOC), Inc., 528 U.S. 167, 190 (2000). “It is the doctrine of mootness, not standing, that addresses whether an intervening circumstance has deprived the plaintiff of a personal stake in the outcome of the lawsuit.” West Virginia v. Env’t Prot. Agency, 597 U.S. 697, 719 (2022) (cleaned up). The defendants’ arguments do not challenge the plaintiffs’ standing at the time the suit was filed, but rather their continued interest in the litigation.

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G.K., by their next friend, Katherine Cooper et al. v. Christopher Sununu, Governor of New Hampshire et al., 2024 DNH 078 (D.N.H. 2024).

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