Mendy Barnett v. Dep't of Children's Services

CourtCourt of Appeals for the Sixth Circuit
DecidedNovember 12, 2020
Docket20-5032
StatusUnpublished

This text of Mendy Barnett v. Dep't of Children's Services (Mendy Barnett v. Dep't of Children's Services) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mendy Barnett v. Dep't of Children's Services, (6th Cir. 2020).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 20a0643n.06

Case Nos. 20-5010/5032

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Nov 12, 2020 MENDY BARNETT, individually and as next ) DEBORAH S. HUNT, Clerk friend of M.G.W. and M.W., ) ) Plaintiff-Appellant/Cross-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE EASTERN DISTRICT OF ) TENNESSEE DANIEL SMITHWICK, ) ) Defendant-Appellee/Cross-Appellant. )

BEFORE: SUTTON, THAPAR, and READLER, Circuit Judges.

CHAD A. READLER, Circuit Judge. As often happens, we have before us competing

interests: the duty of public officials to act reasonably to protect children from harm, and the

fundamental rights of parents to raise their children without government interference. Because the

district court proceedings properly calibrated those considerations, we affirm the various

judgments entered in favor of the state officer.

BACKGROUND

Mendy Barnett and Marc Winters had a long and troubled history with the Tennessee

Department of Children’s Services (DCS). Over a seven-year span, DCS investigated the couple

nine times regarding allegations of neglect, lack of supervision, and drug exposure relating to their

two children, daughter M.G.W. and son M.W. That pattern continued when DCS received a report Case Nos. 20-5010/5032, Barnett v. Smithwick

from a concerned babysitter that the children appeared hungry and dirty. DCS promptly dispatched

social workers to examine the children.

DCS’s efforts, however, were not well-received. Barnett and Winters refused every

attempt by DCS social workers to see the children. Failing on those fronts, DCS enlisted the help

of Daniel Smithwick, DCS’s lead regional attorney. Through Smithwick, DCS obtained an ex

parte order from the juvenile court granting the social workers enhanced investigatory powers.

The order required the parents to “allow entrance to the home, school, or place where the children

are located” for examination of the children. The order also authorized social workers to take

physical custody of the children to conduct medical and forensic examinations.

DCS spent the next three weeks trying to locate the children. With the help of law

enforcement, DCS eventually tracked the children to their paternal grandparents’ home. When a

DCS social worker arrived at the home, the grandparents denied knowing the parents or children

and refused to identify themselves. But when the social worker spotted a small girl who she

suspected to be M.G.W., the grandparents eventually admitted that the girl was the missing

daughter.

During the encounter, the social worker took care to observe M.G.W.’s living conditions.

She was alarmed by what she saw. The social worker observed M.G.W. playing unsupervised,

climbing on pieces of “broken machinery” in the yard, and running around barefoot in tall grass

with snakes present. When asked to see where the children slept, the grandparents led the social

worker to a camper parked in the driveway. Among other worrisome conditions, the camper

lacked utilities and was nearly impassible, littered with rotten food, empty alcohol bottles, and

other garbage.

2 Case Nos. 20-5010/5032, Barnett v. Smithwick

M.G.W. was dirty, sporting scrapes and bruises. When asked about the bruises, the

grandparents explained them away as grease marks from working on a car, an unusual explanation

for a toddler like M.G.W. Suspecting abuse, the social worker asked to question the children’s

parents, and to examine M.G.W.’s infant brother, M.W. The grandparents explained that M.W.

was out running errands with Barnett, and initially refused to contact the parents or comply with

the investigation. When the grandmother eventually relented and called Winters, he refused to

speak with the social worker or return from work. Unable to engage the family, the social worker

called Smithwick. He advised her to invoke the previously obtained juvenile court order and

remove M.G.W. to a hospital for examination.

At the hospital, physicians determined that M.G.W.’s injuries did not show signs of abuse

and were consistent with normal child’s play. When a DCS supervisor contacted the parents about

releasing M.G.W. to them, Barnett “blew up” on her, yelled profanities, and hung up. DCS called

back repeatedly, with no one answering.

In the unusual circumstance of a parent refusing custody of a child, DCS policy requires

officers to explore all other viable familial placement options. Social workers, however, were

reluctant to return M.G.W. to her grandparents’ home. And DCS officers had run through all other

placement options, concluding that every known family member was disqualified under various

DCS policies. Once familial options are exhausted, a DCS attorney may, as a last resort, authorize

extrajudicial removal into state custody without a hearing. Lacking other options, social workers

asked Smithwick to authorize an emergency removal. Smithwick knew of the conditions at the

grandparents’ home and had been in regular communication with DCS social workers.

Nonetheless, he insisted that DCS continue with its efforts to reach the parents.

3 Case Nos. 20-5010/5032, Barnett v. Smithwick

DCS officers called the parents at fifteen-minute intervals for several hours, without

success. Finally, at around 11:30 p.m., Smithwick agreed that social workers had “exhausted their

efforts and . . . had hit a wall.” Smithwick acceded to the social worker’s request and deemed

M.G.W. legally “abandoned” by her parents at the hospital, authorizing DCS to take physical and

legal custody of the child.

The next day, DCS received a temporary order from the juvenile court to formalize the

custody transfer of M.G.W. and to assume custody of her brother, M.W. A formal hearing was set

one business day later. Custody proceedings carried on for about one month, culminating in DCS

voluntarily dismissing the case and releasing M.G.W. and M.W. back into their parents’ custody.

This litigation followed. Barnett, the children’s mother, sued Smithwick and others under

state law and 42 U.S.C. § 1983, claiming procedural due process and Fourth Amendment

violations. At summary judgment, the district court dismissed all Fourth Amendment claims

against Smithwick but denied him qualified immunity on the procedural due process claims

relating to M.G.W.’s removal. At trial, the primary dispute between the parties was whether

exigent circumstances justified the emergency removal without a formal hearing. The district

court denied Smithwick’s motion for judgment as a matter of law, but a jury later granted judgment

in Smithwick’s favor, finding that exigent circumstances justified his removal decision.

In her timely appeal, Barnett challenges the award of summary judgment to Smithwick on

her Fourth Amendment claims. She also challenges various aspects of the trial proceedings with

respect to her procedural due process claim. Smithwick cross-appeals the district court’s denial of

his motion for judgment as a matter of law on the procedural due process claims.

4 Case Nos. 20-5010/5032, Barnett v. Smithwick

PROCEDURAL DUE PROCESS

Jury Instructions. Barnett alleges that the district court committed reversible error when it

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