Caseworker’s Placement Recommendation Was the ‘Catalyst That Led to the Children’s Harm’ and Could Be Basis for Liability, Sixth Circuit Says

“Through Von Sacken’s efforts, plaintiffs went from a neglectful (and in the baby’s case, abusive) home to a living hell, which certainly meets the definition of an affirmative act,” Senior Judge Richard F. Suhrheinrich wrote on behalf of the unanimous panel.