P.C. v. County of Sonoma

CourtDistrict Court, N.D. California
DecidedJune 16, 2025
Docket3:24-cv-02597
StatusUnknown

This text of P.C. v. County of Sonoma (P.C. v. County of Sonoma) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
P.C. v. County of Sonoma, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 P.C., et al., Case No. 24-cv-02597-AMO

8 Plaintiffs, ORDER RE MOTIONS TO DISMISS 9 v. FIRST AMENDED COMPLAINT

10 COUNTY OF SONOMA, et al., Re: Dkt. Nos. 78, 81 Defendants. 11

12 13 Before the Court are the motions to dismiss of Defendants Sonoma County and individual 14 Sonoma County social workers (ECF 78) and Defendant Amy Lafferty (ECF 81). The motions 15 are fully briefed, and because they were suitable for decision without oral argument, the Court 16 vacated the hearing set for May 20, 2025. See Fed. R. Civ. P. 78(b); Civ. L.R. 7-6. This Order 17 assumes familiarity with the facts and procedural history of this case. Having carefully considered 18 the parties’ papers and the arguments made therein, as well as the relevant legal authority, the 19 Court GRANTS IN PART AND DENIES IN PART both motions for the following reasons. 20 I. DISCUSSION 21 Plaintiffs P.C. and M.C. filed the operative first amended complaint on October 31, 2024. 22 Amended Complaint (“Am. Compl.”) (ECF 66). The amended complaint asserts causes of action 23 related to the alleged abuse Plaintiffs suffered at the hands of their adoptive parents, Jose and Gina 24 Centeno (“the Centenos”), and names as defendants Sonoma County and ten Sonoma County 25 social workers (“County Social Workers”),1 the Centenos, the City of Rohnert Park, Officer 26

27 1 The County Social Workers named in the amended complaint are McCay, Jones, Sashital, 1 Gonzalez, Officer Groat, TLC Child and Family Services (“TLC”), and Amy Lafferty, the 2 adoption services representative of the State of California in charge of P.C. and M.C.’s adoption. 3 Plaintiffs bring claims under 42 U.S.C. §§ 1983, 1985 (Counts 1 and 2) against all Defendants; a 4 Monell claim (Count 3), breach of mandatory duty claim (Count 4), intentional infliction of 5 emotional distress (“IIED”) claim (Count 6), and assault claim (Count 7) against Sonoma County 6 and TLC; and a negligence claim (Count 5) against TLC. Plaintiffs have settled their claims 7 against TLC, as well as those against Rohnert Park, Officer Gonzalez, Officer Groat, and TLC. 8 See ECF 107. Further, because Plaintiffs voluntarily dismiss Counts 6 and 7 against Sonoma 9 County, ECF 83 at 6, the causes of action that remain are Counts 1 and 2 against all remaining 10 Defendants, and 3 and 4 against Sonoma County. 11 On December 6, 2024, Sonoma County and the County Social Workers (together, “County 12 Defendants”) filed a motion to dismiss the amended complaint for failure to state a claim, ECF 78, 13 as did Lafferty, ECF 81. Under Rule 12(b)(6) of the Federal Rules of Civil Procedure, a 14 complaint may be dismissed for failure to state a claim for which relief may be granted. Fed. R. 15 Civ. P. 12(b)(6). Rule 12(b)(6) requires dismissal when a complaint lacks either a “cognizable 16 legal theory” or “sufficient facts alleged” under such a theory. Godecke v. Kinetic Concepts, Inc., 17 937 F.3d 1201, 1208 (9th Cir. 2019) (citation omitted). Whether a complaint contains sufficient 18 factual allegations depends on whether it pleads enough facts to “state a claim to relief that is 19 plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. 20 Twombly, 550 U.S. 544, 570 (2007)). A claim is plausible “when the plaintiff pleads factual 21 content that allows the court to draw the reasonable inference that the defendant is liable for the 22 misconduct alleged.” Id. at 678. 23 When evaluating a motion to dismiss, the Court “accept[s] factual allegations in the 24 complaint as true and construe[s] the pleadings in the light most favorable to the nonmoving 25 party.” Manzarek v. St. Paul Fire & Marine Ins. Co., 519 F.3d 1025, 1031 (9th Cir. 2008) 26 (citation omitted). However, “allegations in a complaint . . . may not simply recite the elements of 27 a cause of action [and] must contain sufficient allegations of underlying facts to give fair notice 1 1135 (9th Cir. 2014) (citations omitted). Courts may dismiss a claim “where there is either a lack 2 of a cognizable legal theory or the absence of sufficient facts alleged under a cognizable legal 3 claim.” Hinds Invs., L.P. v. Angioli, 654 F.3d 846, 850 (9th Cir. 2011). Courts should “freely 4 give leave” to amend “when justice so requires.” Fed. R. Civ. P. 15(a)(2). 5 A. County Defendants’ Motion to Dismiss 6 County Defendants move to dismiss all of Plaintiffs’ claims against them, as well as 7 Plaintiffs’ claim for punitive damages against the County Social Workers. See County 8 Defendants’ Motion (“County Mot.”) (ECF 78). The Court addresses each claim and the 9 arguments for dismissal in turn. 10 1. Section 1983 11 Plaintiffs bring two claims against County Defendants under the Fourteenth Amendment 12 for failure to adequately respond to or investigate reports of abuse and for providing false 13 information to a court. Am. Compl. ¶¶ 78-90. “The Fourteenth Amendment substantive due 14 process clause protects a foster child’s liberty interest in social worker supervision and protection 15 from harm inflicted by a foster parent.” Tamas v. Dep’t of Soc. & Health Servs., 630 F.3d 833, 16 842 (9th Cir. 2010). County Defendants argue the County Social Workers are either absolutely 17 immune from liability or that they are entitled to qualified immunity because Plaintiffs fail to 18 allege deliberate indifference. They further contend Sonoma County cannot be held vicariously 19 liable for the County Social Workers. Each argument is addressed in turn below. 20 a. Absolute Immunity 21 “Defendants in § 1983 suits are generally entitled to only immunities that existed at 22 common law.” Rieman v. Vazquez, 96 F.4th 1085, 1090 (9th Cir. 2024). “[S]ocial workers are 23 not afforded absolute immunity for their investigatory conduct, discretionary decisions or 24 recommendations.” Cox v. Dep’t of Soc. & Health Servs., 913 F.3d 831, 837 (9th Cir. 2019) 25 (quoting Tamas, 630 F.3d at 842). Nor are they entitled to absolute immunity from claims relating 26 to “investigative or administrative” activity. Hardwick v. Cnty. of Orange, 844 F.3d 1112, 1115 27 (9th Cir. 2017) (citation omitted). Courts “grant[] state actors absolute immunity only for those 1 v. Gammie, 335 F.3d 889, 896 (9th Cir. 2003) (en banc) (quoting Imbler v. Pachtman, 424 U.S. 2 409, 431 (1976)). Social workers may enjoy absolute immunity related to “discretionary, quasi- 3 prosecutorial decisions to institute court dependency proceedings to take custody away from 4 parents.” Rieman, 96 F.4th at 1090 (citation omitted). Such immunity is only available if the 5 social worker’s “activity or function” is “part and parcel of presenting the state’s case as a generic 6 advocate.” Hardwick, 844 F.3d at 1115.

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P.C. v. County of Sonoma, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-v-county-of-sonoma-cand-2025.