Case Citator › Pittman v. Cuyahoga County Department of Children & Family Services

Pittman v. Cuyahoga County Department of Children & Family Services

Is it still good law? What later courts have actually done to this case.

Criticized by some courts
Court
Sixth Circuit
Citation
640 F.3d 716
Decided
Confirmed treatments
2
Flagged citations read
81 of 81
Citing cases (total)
358
Treatment dates
2011–2021
Criticized by some courts
At least one reviewed court has criticized this case’s reasoning. No reviewed court has overruled it. Pittman v. Cuyahoga County Department of Children & Family Services has been criticized: all 81 flagged citations have been read, and two adverse treatments are listed below. A district court criticized its use of strict scrutiny for executive action.
More on how this was screened

The Sixth Circuit later recognized an exception to Pittman's juvenile-court causation rule when a custody order rests on a bad-faith child-services investigation. Other later opinions continue to apply Pittman's due-process and immunity analysis.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

358 later cases cite Pittman v. Cuyahoga County Department of Children & Family Services; 81 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Pittman v. Cuyahoga County Department of Children & Family Services?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Criticized

  • A district court criticized Pittman's use of strict scrutiny for a social-worker due-process claim as resting on case law predating the Supreme Court's decision in County of Sacramento v. Lewis.

    Kovacic v. Cuyahoga County Department of Children & Family Services · Northern District of Ohio · filed

    But see Pittman, 640 F.3d at 728(applying the strict scrutiny standard but relying on pre-Lewis case law that divided substantive due process claims against executive agents into two types, those based on violations of particular constitutional guarantees and those that shock the conscience);
    Read the full opinion on CourtListener →

Limited

  • The Sixth Circuit recognized an exception to Pittman's juvenile-court causation rule when a custody order rests on a bad-faith child-services investigation.

    Clark v. Stone · Sixth Circuit · filed

    The defendants cite to Pittman v. Cuyahoga County Department of Children & Family Services., where this court held that where the juvenile court has the ultimate authority to do something, social workers cannot be sued for substantive due ... process harms because the court, not the social workers, is the cause of the harms. 640 F.3d 716, 728–29 (6th Cir. 2011). However, as the district court recognized, there is a general exception to this absolute immunity where “the court order is based on a bad-faith child-services investigation.”
    Read the full opinion on CourtListener →

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