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Ernst v. Child and Youth Services of Chester County
United States Court of Appeals for the Third Circuit
108 F.3d 486 (1997)
Facts
Sylvia Ernst (plaintiff) was the sole guardian for her granddaughter, Susanne, from infancy to age nine. Concerns regarding Susanne’s well-being were raised after she would throw tantrums and refuse to leave her grandmother’s side. Thus, local police investigated the matter, revealing that there were warrants for Ernst’s arrest for child neglect and a petition for custody of Susanne in another state. However, the warrants and the petition had since been withdrawn. The police informed Chester County Children & Youth Services (CYS) (defendant) of its investigation findings and the status of the warrants and petition. After another tantrum, CYS took emergency custody of Susanne and placed her on a psychiatric hold for evaluation. Originally, the goal of CYS was reunification. However, over the course of five years, the relationship between Ernst and CYS workers grew contentious, and the goal of CYS became long-term foster placement. A family-court judge eventually granted Ernst full legal custody. Ernst filed suit under 42 U.S.C. § 1983, alleging that by seizing Susanne, the CYS workers violated her substantive and procedural due-process rights. The district court granted summary judgment in favor of the CYS child-welfare workers based on absolute immunity. Ernst appealed.
Rule of Law
Issue
Holding and Reasoning (Stapleton, J.)
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