Sunday, December 8, 2013

Smith v. Organization of Foster Families for Equality and Reform (Offer) case brief

Smith v. Organization of Foster Families for Equality and Reform (Offer) case brief summary
431 U.S. 816 (1977)


CASE SYNOPSIS
Appellee foster parents brought a civil rights class action against appellant state arguing that procedures governing the removal of foster children from foster homes, N.Y. Soc. Serv. Law § 383(2), 400 (1976) and N.Y. Comp. Codes R. & Regs. tit 18, § 450 (1976), violated the Due Process Clause of U.S. Constitutional Amendment XIV. The United States District Court for the Southern District of New York found them defective, and the state appealed.

CASE FACTS
The foster parents alleged on behalf of a class of themselves and children for whom they had provided homes that when a child had lived in a foster home for a year or more, a family was created, and that that family had a "liberty interest" in its survival protected by U.S. Constitutional Amendment XIV. The foster parents claimed that the procedures governing the removal of foster children from foster homes, N.Y. Soc. Serv. Law § 383(2), 400 (1976) and N.Y. Comp. Codes R. & Regs. tit 18, § 450 (1974), failed to protect the interest.

DISCUSSION

  • On appeal, the state challenged the district court's determination that the state laws were constitutionally infirm. 
  • The Court found that it did not need to determine whether a liberty interest existed because, even if it did, the procedures afforded by the state were sufficient to protect that interest. 
  • The Court applied a three-factor test, which evaluated private interest, risk of erroneous deprivation, and governmental interest. 
  • The Court ruled that foster families were provided with a more elaborate trial-type hearing than those required in the context of other administrative determinations and that the procedure was constitutionally sufficient.
CONCLUSION
The Court reversed the judgment of the lower court, determining that the procedures provided by the state for removal of foster children from foster homes were adequate to protect whatever liberty interests the foster parents may have had.


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