This appeal arises from the deaths of three veterans at the Soldiers' Home in Chelsea, Massachusetts, a state-run long-term care facility, after they contracted COVID-19 in the spring of 2020. Representatives of the veterans' estates sued multiple Massachusetts state officials, including the former Secretary of Veterans' Services and the Superintendent of the facility, under 42 U.S.C. § 1983. The plaintiffs alleged that the defendants violated the veterans' substantive due process rights through two primary theories: a negligent response to the pandemic, such as failing to enforce social distancing or testing, and the maintenance of inhumane living conditions, including unsanitary environments and improper restraints. The District Court granted the defendants' motion to dismiss, ruling that the complaint failed to sufficiently allege a constitutional violation and that the defendants were entitled to qualified immunity because the law was not clearly established. The representatives appealed, arguing that the defendants created the danger or had a special relationship with the residents that imposed an affirmative duty to protect them.
The First Circuit affirmed the District Court's decision, focusing on the requirements of substantive due process and qualified immunity. The court reiterated the general rule that a state's failure to protect an individual against harm does not constitute a Due Process violation unless the state actor directly caused the harm. The court analyzed the plaintiffs' claims regarding the pandemic response and living conditions, noting that the complaint alleged failures to act or omissions rather than affirmative acts that directly caused the veterans' deaths. The court rejected the plaintiffs' attempt to rely on precedents regarding proximate causation, stating that the plaintiffs did not identify any third parties who inflicted the injury or explain how the harm was attributable to foreseeable intervening forces. The court also addressed the 'special relationship' exception, which imposes a duty to protect when the state restrains an individual's freedom to act on their own behalf. While the plaintiffs cited cases suggesting that helpless patients in state facilities may be de facto involuntary wards, the court clarified that the state must affirmatively act to restrain the individual's freedom. The court found that prohibiting family visitation during the pandemic did not plausibly allege that the veterans were forced to remain at the facility against their will or were barred from leaving upon request. Consequently, the court held that the plaintiffs failed to allege a violation of clearly established law, and the defendants were entitled to qualified immunity.
The decision affirms the dismissal of the lawsuit, leaving the state officials immune from liability for damages. It reinforces the high bar for establishing substantive due process claims against state actors in non-custodial settings, requiring plaintiffs to allege direct causation or a specific affirmative act that restrains an individual's freedom. The ruling leaves open the question of whether different factual allegations regarding the 'special relationship' exception could survive a motion to dismiss, but it signals that general allegations of negligence or poor conditions are insufficient without a showing of direct state involvement in the harm.
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