The Second Circuit affirmed the district court's dismissal of plaintiffs' claims alleging violations of the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Due Process Clause of the Fourteenth Amendment pursuant to 42 U.S.C. 1983. The district court determined that the claims were barred by the Rooker-Feldman doctrine, collateral estoppel, the statute of limitations, qualified immunity, and lack of standing. The district court also dismissed some claims for failure to state a claim.
The court concluded that, under both federal and Connecticut law, the issue at the core of the parties' dispute is whether DCF reasonably accommodated plaintiffs' actual or perceived disabilities in providing services and programs to assist their reunification with their children. The court explained that the issue was actually litigated and necessarily determined by Connecticut courts. Therefore, the district court correctly granted DCF's motion to dismiss on collateral estoppel grounds. The court did not reach the merits of the parties' arguments regarding the Rooker-Feldman doctrine, Connecticut's statute of limitations, or plaintiffs' standing to seek prospective injunctive relief. View "Watley v. Department of Children and Families" on Justia Law
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