Johnson v. Winters Tomasi

CourtVermont Superior Court
DecidedNovember 4, 2025
Docket25-cv-159
StatusUnknown

This text of Johnson v. Winters Tomasi (Johnson v. Winters Tomasi) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johnson v. Winters Tomasi, (Vt. Ct. App. 2025).

Opinion

VERMONT SUPERIOR COURT CIVIL DIVISION Washington Unit Case No. 25-CV-00159 65 State Street Montpelier VT 05602 802-828-2091 www.vermontjudiciary.org

Kerrie Johnson v. Christopher Winters et al

Opinion and Order on the State’s Motion to Dismiss and Ms. Johnson’s Motion to Strike and Seal

This case arises out of complaints by Plaintiff Ms. Kerrie Johnson (and potentially

others) of alleged abuse of her children by their father (her now ex-husband) to

Defendant the Department for Children and Families (DCF). The complaints resulted in

investigations or assessments, but no abuse complaint ever was substantiated. Due to

Ms. Johnson’s prior employment with DCF (and potentially additional reasons), to avoid

conflicts, the investigations and assessments were undertaken by DCF’s Residential

Licensing and Special Investigations Unit or the Adult Protective Services Division of

Defendant the Department of Aging and Independent Living (DAIL).1 Ms. Johnson has

repeatedly requested that DCF disclose to her the relevant “redacted investigation files”

pursuant to 33 V.S.A. § 4921(c)(1) (parental right to redacted investigation files), but the

production has largely been refused. She claims that DCF also has refused to produce, in

violation of 33 V.S.A. § 4921(d)(6), records involving her children that were requested by

the Office of the Child, Youth, and Family Advocate (OCYFA). Ms. Johnson asks the

1 The named defendants are the Commissioners DCF and DAIL, who have been sued in

their official capacity only. “In an official-capacity claim, the relief sought is only nominally against the official and in fact is against the official’s office and thus the [governmental entity] itself.” Lewis v. Clarke, 581 U.S. 155, 162 (2017) (citations omitted. Accordingly, the Court refers to the Defendants as DCF and DAIL when context requires and, collectively, the State. Order Page 1 of 15 25-CV-00159 Kerrie Johnson v. Christopher Winters et al Court to order the State to disclose the requested records to her (Claim 1) and to issue a

declaratory ruling as to OCFYA’s right to the records it requested (Claim 2).2

The State has filed a motion to dismiss for lack of subject-matter jurisdiction, Vt.

R. Civ. P. 12(b)(1), and—at least nominally—for failure to state a claim, Vt. R. Civ. P.

12(b)(6). It argues that Ms. Johnson’s claim of right to the redacted records (Claim 1)

fails on the merits and that the Court lacks subject-matter jurisdiction as a result. It

also argues that Ms. Johnson lacks standing to bring her claim regarding OCFYA’s right

to records (Claim 2). A motion seeking dismissal for lack of standing is considered under

Rule 12(b)(1), which addresses subject-matter jurisdiction. 5B Arthur R. Miller and A.

Benjamin Spencer, Fed. Prac. & Proc. Civ. § 1350 (4th ed.). The State nowhere specifies

what part of its motion it believes is subject to Rule 12(b)(6) rather than Rule 12(b)(1),

however.

The State submitted numerous documents in support of its dismissal motion,

likely indicating its belief that it is proper to do so when subject-matter jurisdiction is at

issue. Those records are relevant only to its argument seeking the dismissal of Claim 1;

they are irrelevant to its Claim 2 standing argument. In response, Ms. Johnson filed a

motion to “strike and seal” two of those exhibits, arguing that they are confidential by

statute, unnecessarily reveal her children’s private medical information, and reveal her

contacts with DCF or DAIL during abuse investigations. The State did not oppose

sealing those exhibits but has opposed striking them based on its understanding of the

relevant statutes. The Court temporarily sealed the two exhibits pending additional

2 Ms. Johnson did not separate her claims into separate counts. For ease of reference, the Court refers to them as Claims 1 and 2. Order Page 2 of 15 25-CV-00159 Kerrie Johnson v. Christopher Winters et al briefing, in the course of which Ms. Johnson extended her request to include all exhibits

submitted by the State with its dismissal motion.

I. The State’s Motion to Dismiss

A. Framing Claim 1

Ms. Johnson’s complaint is unclear as to the legal basis for either of the claims

asserted, but she states that she is bringing them pursuant to Rules 57 (declaratory

judgment), 65 (injunctions), and 75 (review of governmental action). Rules 57, 65, and 75

are procedures; they are not substantive claims on their own. Rules 57 and 65 apply to

relief only and indicate nothing about what substantive claim might lead to such relief.

Rule 75, on the other hand, is the procedure that applies to certain claims, usually those

seeking review in the nature of certiorari, mandamus, or prohibition. Reporter’s Notes—

Vt. R. Civ. P. 75.

There is no statutory right to appeal the denial of the records that Ms. Johnson

requested, and review in the nature of certiorari and prohibition makes no sense in this

context. The State thus reasons that Ms. Johnson’s Claim 1 seeks review in the nature

of mandamus. See Ahern v. Mackey, 2007 VT 27, ¶ 8, 181 Vt. 599, 602 (“The purpose of

mandamus is generally to require a public official or body to perform a simple ministerial

duty imposed by law, although it may be available to enforce even discretionary duties

‘[w]here there appears, in some form, an arbitrary abuse of the power vested by law in an

administrative officer . . . which amounts to a virtual refusal to act or to perform a duty

imposed by law.’” (citation omitted)). Ms. Johnson does not dispute that contention.

Accordingly, the Court concludes that Ms. Johnson’s Claim 1 seeks mandamus review.

Order Page 3 of 15 25-CV-00159 Kerrie Johnson v. Christopher Winters et al B. Rule 12(b)(1) vs. Rule 12(b)(6)

As noted, the State submitted substantial extrinsic evidence with its motion to

demonstrate that Ms. Johnson’s Claim 1 lacks merit. “A court may consider evidence

outside the pleadings in resolving a motion to dismiss for lack of subject-matter

jurisdiction [under Rule 12)(b)(1)].” Conley v. Crisafulli, 2010 VT 38, ¶ 3, 188 Vt. 11, 14.

Generally, with limited exceptions not relevant here, a Court may not consider evidence

outside the four corners of the complaint (and any attachments to it) on a motion to

dismiss for failure to state a claim under Rule 12(b)(6). See Nash v. Coxon, 152 Vt. 313,

314–15 (1989) (“[I]f matters outside the pleadings are presented and not excluded by the

court, the motion to dismiss must be treated as one for summary judgment.” (internal

quotation and citation omitted)).

Rule 12(b)(1) plainly applies to the State’s standing argument. The extrinsic

evidence that the State submitted, however, appears only tangentially relevant to that

part of its motion. Otherwise, the State’s contention that the lack of merit as to Claim 1

negates the existence of the Court’s subject-matter jurisdiction may well misapprehend

the difference between a court’s jurisdiction and a claim’s merits. As the U.S. Supreme

Court definitively explained long ago:

Jurisdiction . . . is not defeated . . . by the possibility that the averments might fail to state a cause of action on which petitioners could actually recover. For it is well settled that the failure to state a proper cause of action calls for a judgment on the merits and not for a dismissal for want of jurisdiction.

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Johnson v. Winters Tomasi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-winters-tomasi-vtsuperct-2025.