Supreme Court of Georgia

Georgia Department of Human Services, Division of Family and Children Services v. Christopher Steiner.

June 18, 2018815 S.E.2d 883

Summary

The court reversed the superior court and held that Steiner failed to show that his inclusion in Georgia's child-abuse registry deprived him of a constitutionally protected liberty or property interest, so his as-applied and facial due-process challenges failed. The court also held that the registry is civil rather than criminal, that the investigator's role does not violate separation of powers, and that some evidence supported the administrative finding that Steiner committed child abuse. Justice Peterson, concurring, agreed that Steiner was not entitled to relief but would have criticized DFCS's incomprehensible notice and lack of meaningful process.