La Belle v. County of St. Lawrence
This case involves three consolidated actions arising from the temporary removal of two minor children, Randy and Jodi La Belle, by St. Lawrence County Department of Social Services and Massena police officers while their parents, Albert and Joyce La Belle, were on vacation. The parents (Action No. 1) sued for intentional infliction of emotional distress and civil rights violations (42 U.S.C. § 1983). The children (Action Nos. 2 and 3) brought claims for false arrest, false imprisonment, and civil rights violations. This appeal reviews the denial of defendants' motions to dismiss the complaints by the Supreme Court at Special Term. The appellate court modified the order, dismissing the parents' entire action, certain civil rights claims against the County of St. Lawrence and the Village of Massena, and all punitive damages claims against municipalities and for State law claims in Action Nos. 2 and 3. The infant plaintiffs were left with causes of action for false arrest, false imprisonment, and section 1983 claims against the Department of Social Services and individual defendants, with punitive damages claims remaining only against individual defendants for the section 1983 causes of action.