Orlik Ex Rel. Orlik v. Dutchess County
Plaintiff Sheryl Orlik, on behalf of herself and her son Jared, sued Dutchess County, the Dutchess County Department of Social Services (DSS), and several individual defendants under 42 U.S.C. § 1983. Orlik alleged violations of procedural due process, substantive due process, Fourth Amendment rights, and malicious prosecution stemming from the allegedly wrongful removal of Jared from her custody. The defendants moved for summary judgment, asserting qualified immunity. The court granted summary judgment, finding that the individual defendants were entitled to qualified immunity because the procedural due process claim was denied due to a brief removal period, the substantive due process claim lacked egregious official conduct, the Fourth Amendment claim was supported by a reasonable belief in probable cause, and the malicious prosecution claim was not clearly established for civil Family Court proceedings. The motion was deemed moot for defendant Allers as he was sued only in his official capacity.