Hughes v. Stanley County School District

KONENKAMP, Justice

(dissenting).

[¶ 20.] This is one of those decisions, as Justice Jackson once reflected, in which the reasons given for the decision are more important than the decision itself. For the majority, the result in this case is justified because there exists an irreconcilable contradiction between the School Board’s policy and South Dakota law. The Board chose to fire Hughes based on a violation of its policy, and this Court on remand would not let it consider whether her violation of state law would have resulted in her dismissal. Therefore, Hughes wins. South Dakota’s children may be the losers, however, for this Court turns mandated child abuse reporting into an almost meaningless muddle.

[¶ 21.] After today, no matter how graphic a child’s complaint of abuse may be, educators who are required to report it, but who instead conduct their own private inquiry, may excuse their unlawful conduct by simply claiming that their personal investigation failed to turn up satisfactory proof. That is the precise opposite of what the law intends. Our laws entrust the investigation of child abuse to law enforcement and social service professionals. “It is the duty of the investigating agency to determine whether the report was founded.” Matter of Kimberly S.M., 226 A.D.2d 85, 649 N.Y.S.2d 588, 591 (1996). Both federal and state laws require educators and school counselors to “report” abuse whenever they reasonably suspect it.4 The primary intent of these reporting laws is to protect children, not to shield school officials who evade their duties.

[¶ 22.] In this case, the child told Hughes, a school counselor, that her father asked her to touch his penis. She had earlier told Hughes of other sexually inappropriate things her father had done in her presence. In response, Hughes did *56the very thing our child abuse reporting laws seek to prevent. She conducted her own private investigation. In contacting the child’s parents, Hughes decided, “I will go straight to the source. I will blow the whistle if it is happening or confront [the child] about her habitual lying.” When educators intentionally ignore their legal duty to immediately report suspected child abuse, they endanger not only the child in question, but also other unknown children who are being abused or who are at high risk of becoming abused. Indeed, it was not until the father here was charged and convicted of sexually assaulting a neighbor child that his daughter’s earlier complaint to Hughes came to light.

[¶ 28.] Usurping the role of state investigators, Hughes took it upon herself to find out “if it was happening.” The School Board’s policy on this point was clear: “school employees shall not contact the child’s family or any other persons to determine the cause of the suspected abuse or neglect. It is not the responsibility of the school employees to prove that the child has been abused or neglected, or to determine whether the child is in need of protection.” Although here this Court, in combination with its decision in Hughes I, manages to excuse her violation of this policy, Hughes was nonetheless bound to follow state law.

[¶ 24.] In the first appeal, this matter should have been remanded to the School Board on the question whether Hughes would have been fired for violating state law in conducting her own child abuse investigation. Hughes v. Stanley County School Bd., 1999 SD 65, 594 N.W.2d 346 (Hughes I) (Konenkamp, J., dissenting). After reviewing Hughes’ own rendition of events, it seems inconceivable that the Board would not have made the same decision it did on the question whether she violated her contract. Her contract required her to obey state law.

[¶ 25.] In South Dakota, reporting is mandatory whenever a teacher or counsel- or has “reasonable cause to suspect” child abuse. SDCL 26-8A-8. Contrary to this Court’s distorted interpretation in Hughes I, “reasonable cause to suspect” is not the same as “probable cause” in criminal law.5 The United States Supreme Court distinguished between these terms, concluding that “reasonable cause to suspect” is a less stringent standard than “probable cause.” United States v. Ramsey, 431 U.S. 606, 612-13, 97 S.Ct. 1972, 1977, 52 L.Ed.2d 617 (1977). Teachers and school counselors are not magistrates commissioned to rule on questions of legal sufficiency. If they have reasonable suspicion of abuse, they have to report it. As Hughes herself said, the child’s comments raised a “red flag.” That is all it takes.

[¶ 26.] A Wisconsin court properly defined “reasonable cause to suspect” in the context of reporting child abuse:

[T]he phrase “reasonable cause to suspect” fairly notifies a person of ordinary intelligence that if there is a reasonable basis to suspect that child abuse has occurred, that person must make a report to the appropriate agency. Whether a person possesses a reasonable suspicion that child abuse has occurred is not subject to misunderstanding. This requirement examines the totality of the facts and circumstances actually known to, and as viewed from the standpoint of, that person.

State v. Hurd, 135 Wis.2d 266, 400 N.W.2d 42, 45 (1986); (see generally, 2 Kramer, *57Legal Rights of Children, § 16.15, pp. 59-60 [2d ed.]). “Reasonable cause to suspect” occurs whenever a teacher or counselor entertains a reasonable suspicion, based on training and experience. If, as she claims, Hughes had no reasonable suspicion, then why would she have felt the need to contact the child’s parents to find out “if it was happening”? Such a felt need is as close to a reliable mark of reasonable suspicion as we are ever likely to find.

[¶ 27.] Educators must appreciate how important their role is in stopping child abuse and neglect. When a school official reasonably suspects child abuse, the report must be made “immediately.” SDCL 26-8A-8. Truly, it is not always easy or comfortable to report abuse, and sometimes reporting takes courage.6 Our message to professionals obligated to report should be clear: it is against the law not to report suspected abuse immediately. Of course, it is understandable that a counsel- or like Hughes could make an error in judgment. If that were the reason for excusing her mistake, few would challenge it. But the Court in Hughes I and in this decision restructures the law to accomplish its end. For the sake of our children, however, I hope that South Dakota educators continue to follow the clear wording of our state statute, instead of this Court’s unfortunate reinterpretation of it.

. See Child Abuse Prevention and Treatment Act (CAPTA), 42 USC 5106g; SDCL 26-8A-3; SDCL 26-8A-2(8). Under CAPTA, sexual abuse includes the employment, use, persuasion, inducement, enticement, or coercion of any child to engage in, or assist any other person to engage in, any sexually explicit conduct or simulation of such conduct for the purpose of producing a visual depiction of such conduct. It also includes the rape, and in cases of caretaker or inter-familial relationships, statutory rape, molestation, prostitution, or other form of sexual exploitation of children, or incest with children.

. In Hughes /, this Court took the term “reasonable cause to suspect,” omitted the last two words, then defined the remaining words "reasonable cause” to mean the same as "probable cause.” See Hughes I at ¶ 30, 594 N.W.2d 346.

. Linda L. Hale, Ph.D. and Julie Underwood, J.D., Ph.D., Child Abuse: Helping Kids Who Are Hurting, 74 MarqLRev 560, 573 (1991).