Jaklin Suzeth Gotay & Others v. Juliann Creen & Others

Summary

The court held that children in State-regulated foster care have a substantive due process right to a reasonably safe foster-home environment. It nevertheless reversed the denial of summary judgment because, even assuming the department employees acted with deliberate indifference or departed substantially from professional standards, their omissions were not the proximate cause of the children's injuries. The supervisory employees also could not be liable without an underlying constitutional violation, so all department employees were entitled to qualified immunity.