## Facts

- Westmoreland County Children and Youth Services (WCCYS) received an anonymous Childline report alleging Dr. Henry Croft was sexually abusing his minor daughter, Chynna.
- The report referenced that Chynna slept with her parents and that she had previously gone to a neighbor’s home while naked and said she was “sleeping with mommy and daddy.”
- Caseworker Carla Danovsky, accompanied by a state police trooper, went to the Croft home the same night to investigate; Dr. Croft consented to interviews.
- Dr. Croft provided a non-abusive explanation for the “naked outside” incident, stated it occurred months earlier, and offered a witness (the child’s nanny/babysitter) for corroboration.
- Dr. Croft acknowledged family practices that could appear suspicious in isolation (e.g., child seeing parents nude; travel to places where nude beaches are common; applying medicated cream to a rash) but denied abuse.
- The interviews and investigation did not yield objective evidence of sexual abuse, and the caseworker remained uncertain whether abuse occurred.
- Despite the lack of corroboration, Danovsky told Dr. Croft that unless he left the home and separated from Chynna until the investigation concluded, WCCYS would remove Chynna immediately and place her in foster care.
- Dr. Croft left the home under threat of his child’s removal.
- The Crofts sued under 42 U.S.C. § 1983, alleging violation of their Fourteenth Amendment liberty interest in family integrity; the district court granted summary judgment to defendants.

## Issues

1. Whether child-protective officials violate the Fourteenth Amendment substantive due process right to family integrity by coercing a parent to leave the home under threat of foster-care placement, absent reasonable and articulable suspicion of abuse supported by reliable evidence.
2. Whether summary judgment was proper where a factfinder could conclude the agency’s forced separation decision was arbitrary and unreasonable in relation to the evidence obtained during the investigation.

## Decision

- The Third Circuit reversed the grant of summary judgment for defendants and remanded for further proceedings.
- The court held the record could support a finding that the state actors lacked reasonable grounds to force Dr. Croft’s separation from his child.
- The court concluded that, given the uncorroborated anonymous report and the absence of objective evidence after investigation, the coercive ultimatum could be found arbitrary and unreasonable, amounting to a substantive due process violation.

## Legal Principles

- Parents and children have a constitutionally protected liberty interest in family integrity, including companionship, care, custody, and management of children, safeguarded by the Fourteenth Amendment.
- The state has a legitimate interest in protecting children from abuse, but significant interference with family integrity must be justified by reasonable and articulable suspicion grounded in reliable evidence.
- An uncorroborated anonymous allegation, coupled with an investigation yielding no objective evidence of abuse, may be insufficient to justify coercive separation measures.
- “Voluntary” separation is not voluntary for constitutional purposes when induced by an imminent threat of state removal of a child; such coercion may constitute state-imposed disruption of the family unit.
- Summary judgment is inappropriate where the evidence permits a finding that child-protective action was so arbitrary and unreasonable as to violate substantive due process.

## Conclusion

The Third Circuit held that coercing a parent to leave the home under threat of immediate foster-care placement, without reasonable and reliable grounds to suspect abuse after investigation, can violate the family’s substantive due process right to family integrity, requiring reversal of summary judgment and remand.


Croft v. Westmoreland Cnty. Child. & Youth Servs., 103 F.3d 1123 (3d Cir. 1997)