Western District of Pennsylvania

Hayes v. Erie County Dep’t of Children & Youth, 804 F.Supp.2d 356 (W.D. Pa. 2011). LIABILITY, CHILD WELFARE AGENCIES
In lawsuit against Pennsylvania child welfare agency and its employees alleging violation of federal constitutional rights after teen’s murder by adoptive mother, defendants were not liable since harm was inflicted by a private person; government officials may only be found liable for alleged violation of federal constitutional rights arising from harm inflicted by private individuals in limited circumstances and plaintiffs failed to establish such circumstances.