Calgaro v. St. Louis County

919 F.3d 1054 (2019)

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Calgaro v. St. Louis County

United States Court of Appeals for the Eighth Circuit
919 F.3d 1054 (2019)

Facts

In 2015 minor child E.J.K. moved out the home of her mother, Anmarie Calgaro. E.J.K. went to a legal aid office and got a letter stating that her parents had given up custody of her and that E.J.K. was now emancipated. Although this letter did not emancipate E.J.K., which required a court order, E.J.K. used the letter to acquire benefits from St. Louis County (defendant) for housing and gender-transition treatment. E.J.K. showed the letter to medical provider Park Nicollet Health Services (Park) (defendant) for gender-transition treatment. E.J.K. showed the letter to Fairview Health Services (Fairview) (defendant) for prescription medication. Neither provider knew that E.J.K. could not legally consent to the treatment. When E.J.K.’s mother requested E.J.K.’s medical records, Park and Fairview denied her requests. Calgaro sued St. Louis County, the county’s interim director of public health and human services (defendant), in her official capacity and as an individual, Park, and Fairview. Calgaro named E.J.K. in the suit as an interested party. Calgaro believed these defendants had violated her fundamental right to parent her child under the Due Process Clause and that Park and Fairview had terminated her parental rights related to her child’s medical treatment. Calgaro sought summary judgment against St. Louis County under 42 U.S.C § 1983. St. Louis County also sought summary judgment on the pleadings. Park and Fairview sought dismissal of Calgaro’s complaint for failure to state a claim. Calgaro also sought a declaratory judgment and an injunction preventing the defendants from providing further services to her children until a court had ruled on the status of her parental rights. E.J.K. turned 18 by the time of trial. A district court granted summary judgment in favor of each defendant and dismissed Calgaro’s complaint with prejudice because she had failed to state a claim under 42 U.S.C § 1983. Calgaro appealed.

Rule of Law

Issue

Holding and Reasoning (Colloton, J.)

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