J.S.H. v. Newton

CourtCourt of Appeals for the First Circuit
DecidedJanuary 14, 2026
Docket24-1832
StatusPublished

This text of J.S.H. v. Newton (J.S.H. v. Newton) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.S.H. v. Newton, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1832

J.S.H., in her individual capacity, and as legal guardian and on behalf of a minor child known as G.H.,

Plaintiff, Appellant,

v.

ALICE NEWTON; MASSACHUSETTS GENERAL HOSPITAL,

Defendants, Appellees.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Margaret R. Guzman, U.S. District Judge]

Before

Montecalvo, Kayatta, and Rikelman, Circuit Judges.

Luke Rosseel, with whom Rosseel Law, John T. Martin, Michaela Weaver, and Sullivan & Sullivan, LLP were on brief, for appellant.

Christine D. Cooledge, with whom John D. Cassidy, Madeline P. Poole, and Ficksman & Conley, LLP were on brief, for appellee Alice Newton.

Emily A. Moellers, with whom Daniel E. Murphy and Faggiano & Associates, P.C. were on brief, for appellee Massachusetts General Hospital. January 14, 2026

- 2 - RIKELMAN, Circuit Judge. This tragic case concerns

G.H., a child who suffered from debilitating medical conditions

that required extensive treatment throughout his short life.

During G.H.'s treatment in 2018, Dr. Alice Newton, a specialist at

Massachusetts General Hospital (MGH), reported suspected medical

child abuse of G.H. by his mother, J.S.H. After an investigation,

that report was deemed unsubstantiated. Several years later,

J.S.H. filed this lawsuit against Dr. Newton and MGH, bringing

state-law emotional distress claims and federal claims, including

a disability discrimination claim against MGH under Section 504 of

the Rehabilitation Act of 1973, 29 U.S.C. § 794(a). The district

court granted summary judgment to Dr. Newton and MGH, concluding

that J.S.H. had failed to offer enough facts to send the case to

trial. We agree with the district court's ruling and thus affirm.

I. BACKGROUND

A. Relevant Facts1

In 2011, J.S.H.'s daughter died at the age of four from

a mitochondrial disorder, a long-term, often genetic disorder that

adversely affects the body's mitochondria but is difficult to

In reviewing the district court's summary judgment ruling, 1

we recount the facts in the record in the light most favorable to J.S.H. and G.H., drawing all reasonable inferences in their favor. See Appleton v. Nat'l Union Fire Ins. Co. of Pittsburgh, 145 F.4th 177, 181 (1st Cir. 2025) (citing Sutherland v. Peterson's Oil Serv., Inc., 126 F.4th 728, 734 (1st Cir. 2025)).

- 3 - diagnose.2 Her daughter had been receiving treatment at Boston

Children's Hospital, and because of the "complex and frustrating

nature" of the disorder, the hospital conducted an internal ethics

review to evaluate the parents' and medical team's actions. In

the end, the ethics review concluded that both the parents and

medical team had acted appropriately.

Shortly after J.S.H.'s daughter died, her son, G.H.,

also began exhibiting concerning health symptoms, and the family

once again sought care at Boston Children's Hospital. Among other

symptoms, G.H. had poor muscle tone and needed medical assistance

to oxygenate and receive nourishment. As a result, G.H. required

extensive, ongoing treatment and specialized services from a team

of highly skilled medical providers. His clinical team came to

suspect that he, like his sister, suffered from a mitochondrial

disorder. G.H. continued to suffer from this "complex

constellation of multi-systemic symptoms" for most of his life.

Ultimately, there was "no unifying or confirmed diagnosis" that

fully explained his condition.

When G.H. began treatment at Boston Children's Hospital,

Dr. Newton was the head of the hospital's child protection team.

In that role, she became familiar with both G.H. and J.S.H.

2 J.S.H. relies on and cites to allegations in the amended complaint in setting out certain background facts. We recite these facts as if they were part of the summary judgment record, given that the defendants do not dispute them.

- 4 - Dr. Newton's position at Boston Children's Hospital rendered her

a "mandated reporter" of suspected child abuse under Massachusetts

law. Mass. Gen. Laws ch. 119, § 51A(a). As a mandated reporter,

she was legally obligated to file a "51A report" with the

Massachusetts Department of Children and Families (DCF) if she had

"reasonable cause to believe that a child [was] suffering physical

or emotional injury resulting from . . . abuse inflicted upon him

which cause[d] harm or substantial risk of harm to the child's

health or welfare."3 Id.

In November 2011, Dr. Newton filed a 51A report about

G.H. with DCF, alleging medical child abuse4 based on her suspicion

that J.S.H. had been misrepresenting G.H.'s health status to his

pediatrician. As grounds for the report, Dr. Newton cited what

she viewed as inconsistencies between J.S.H.'s descriptions of

G.H.'s health and G.H.'s behavior and level of functioning during

We cite to the language of the statute as it existed at the 3

time of the relevant events in this case. Medical child abuse, also known as "Munchausen syndrome by 4

proxy," involves a person, typically a parent, who "fabricates or exaggerates illnesses or physical ailments suffered by another person, typically the child of [that parent]." In re Adoption of Willamina, 881 N.E.2d 771, 772 n.3 (Mass. App. Ct. 2008). "Its effect on the cared-for individual results from the obstacles it creates for health care providers striving to identify the cared-for individual's nonexistent illness, thereby making the matter worse." N.J. Dep't of Child. & Fams. v. L.O., 213 A.3d 187, 189 n.1 (N.J. Super. Ct. App. Div. 2019) (citing medical dictionaries).

- 5 - his hospital stays. At the time, G.H. was three years old. DCF

ultimately determined that the report was unsubstantiated.

After Dr. Newton filed the 51A report, J.S.H. switched

G.H.'s care from Boston Children's Hospital to Tufts Medical

Center. The parties agree that from 2011 until August 2018, Dr.

Newton did not have any contact with J.S.H. or G.H. Nevertheless,

DCF received additional 51A reports about G.H. during that period,

although the parties have not pointed to anything in the record

that indicates who made such reports. DCF determined that those

additional reports were also unsubstantiated.

In the time period between Dr. Newton's initial 51A

report in 2011 and the events that led to this lawsuit, Dr. Newton

switched employers. In 2013, she became the Medical Director of

the Child Protection Program at MGH. The MGH Child Protection

Program specializes in identifying and responding to suspected

child abuse and provides children's medical providers with

information related to suspected child abuse. In her role at MGH,

Dr. Newton continued to be a mandated reporter of suspected child

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J.S.H. v. Newton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jsh-v-newton-ca1-2026.