Civil Rights Matter Involving Compulsory Medical Treatment and Parental Rights
PJ v. Wagner, No. 08-4197, concerned a civil rights action claiming that various state officials wrongfully attempted to force a child to undergo medical treatment (chemotherapy). The court of appeals affirmed summary judgment for defendants in part, holding that: 1) a lower federal court would necessarily have to review and reject certain state-court judgments in order for plaintiffs to succeed on their malicious prosecution claims; 2) defendant-prosecutor's representations in a state court proceeding were intimately associated with the judicial process and her role as an advocate for the state; 3) plaintiffs' right to direct their son's medical care in this case--if any right indeed exists in such circumstances--was not clearly established at the time they alleged the right was violated; and 4) plaintiffs failed to show that any defendant imposed an undue burden on their relationship with the child and therefore failed to show a violation of their associational rights. However, the judgment is reversed in part where plaintiffs' malicious prosecution claims necessarily invite federal-court undoing of two adverse state-court orders, and thus the Rooker-Feldman doctrine bars such claims.
As the court wrote: "There is perhaps no more delicate constitutional barrier protecting individual freedom from governmental interference than that which protects against state interference with parental autonomy. The Supreme Court has long recognized that "[t]he child is not the mere creature of the state," Pierce v. Society of Sisters, 268 U.S. 510, 535 (1925), and that "the custody, care and nurture of the child reside first in the parents, whose primary function and freedom include preparation for obligations the state can neither supply nor hinder." Prince v. Massachusetts, 321 U.S. 158, 166 (1944). It is also well settled, however, that "[a] democratic society rests for its continuance upon the healthy, well-rounded growth of young people into full maturity," and that states "may secure this against impeding restraints and dangers within a broad range of selection." Id. at 168. Because of the importance of parental rights and the concomitant interest of the state in the health and safety of minor children within its borders, the intersection of individual freedom and state authority is always difficult to traverse when a child's life is at stake. This case arises at this difficult constitutional intersection and involves both parents and state actors who genuinely sought to do what they believed was best for a child who was tragically stricken with a life-threatening illness. We have jurisdiction under 28 U.S.C. § 1291, and for the reasons discussed below we REVERSE in part and AFFIRM in part the decision of the district court."
- Full Text of PJ v. Wagner, No. 08-4197
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