Beggs v. State, Department of Social & Health Services

171 Wash. 2d 69, 247 P.3d 421 (2011)

From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Beggs v. State, Department of Social & Health Services

Washington Supreme Court
171 Wash. 2d 69, 247 P.3d 421 (2011)

  • Written by Liz Nakamura, JD

Facts

Tyler DeLeon, a seven-year-old child, died of dehydration and starvation. Carole DeLeon had adopted Tyler and his siblings from foster care through the Washington Department of Social and Health Services (DSHS) (defendant). DSHS paid Carole a monthly stipend for each adopted child. During Tyler’s time with Carole, there were 23 reports to child protective services (CPS) about suspected physical and sexual abuse in the home. While under Carole’s care, Tyler dropped to the fifth weight percentile for his age; Tyler weighed only 28 pounds at the time his death. Prior to Tyler’s death, he was treated by Dr. David Fregeau (defendant) at the Rockwood Clinic (defendant). After Tyler’s death, DSHS removed Tyler’s siblings from Carole’s home. Breean Beggs (plaintiff), as the personal representative of Tyler’s estate and the guardian ad litem for Tyler’s siblings, sued DSHS, Fregeau, and Rockwood for failure to report child abuse. DSHS, Fregeau, and Rockwood moved for summary judgment, arguing (1) Washington’s mandatory reporting statute did not imply a civil remedy, only a criminal penalty; and (2) physicians could only be sued under Washington’s medical-malpractice statute, not the mandatory reporting statute. The trial court granted summary judgment. Beggs appealed.

Rule of Law

Issue

Holding and Reasoning (Sanders, J.)

Dissent (Alexander, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 814,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 814,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 814,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership