Southerland v. Woo
This case involves a father and his now-grown children suing Timothy Woo, a former caseworker for the New York City Administration for Children’s Services (ACS), under 42 U.S.C. § 1983. Plaintiffs alleged Woo made false statements or omitted information to obtain a Family Court order for entry into their home (Fourth Amendment), and then improperly removed the children without court approval (Fourth and Fourteenth Amendments). After multiple appeals and a mistrial, a jury found in favor of the plaintiffs on both claims. The court granted Woo qualified immunity for the Entry Order claim, finding his misstatements immaterial to probable cause. However, the court denied qualified immunity for the children's removal, concluding that no reasonable caseworker would have believed emergency circumstances warranted immediate seizure without a court order, especially given ACS policies and available alternatives. The court also rejected Woo's arguments for judicial estoppel and the application of *Cameron v. Fogarty*.