State Interference on the Right to Family Integrity: Implications of Chambers v. Sanders

Introduction

In May 1987, Danny Burton, a 19-year old Black male in Detroit was charged with the murder of a young man, Leonard Ruffin, who was shot in an alley. Danny was convicted of first degree murder and sentenced to life without parole. But, it turned out that Danny was coerced and manipulated by Detective Ronald Sanders into giving a false confession leading to his conviction.

Following Danny’s release in 2019, Danny’s two sons filed suit against Detective Sanders claiming that the wrongful conviction of their father violated the constitutional right to family integrity. Danny’s wrongful conviction meant that his two sons did not see their father from childhood to adulthood. The Chambers v. Sanders case questions the extent to which surviving family members have a right to family integrity when another family member was wrongfully convicted by the state.

Definition of Family Integrity

The right to family integrity refers to the fundamental rights that parents have over the control of their children. This encompasses the care, custody, and other private decisions that a family can make without the interference of the state. Family integrity ensures that family units have autonomy over the state to make independent decisions regarding aspects of their family lives such as education and religion.

But, this right to family integrity does not mean the state cannot interfere with family units. When a child’s safety and well-being is endangered, the state may interfere to ensure family members are not abusing or mistreating the child. This relationship between the family and state is what the concept of family integrity tries to maintain. 

Historical Context Regarding Family Integrity

The Supreme Court had to define and redefine the relationship between the family and the state multiple times. Meyer v. Nebraska of 1923 established that parents have the liberty to educate their children in their own way noting that the state cannot encroach upon this liberty because it falls under the Due Process Clause of the fourteenth amendment. 

Later on, Pierce v. Society of Sisters 1925 also used the decision made in Meyer to oppose an Oregon statute requiring students to attend public schools. This statue conflicted with the liberty of parents to decide if they wanted their children to attend public or private schools. This provided families with the flexibility to think about how they wanted their children to grow up and be educated.  

Implications of Family Integrity

Although there have been many instances where the state may have interfered with a family unit. It is especially difficult to prove that they did so with the intent to destroy the well being of the family. Even if state actors like the one in Chambers v. Sanders was the main culprit in the wrongful incarceration, it is difficult to prove that the wrongdoing was caused with the intent to sever familial ties. 

Rather than revising the need for there to be intent in severing familial ties, it may be practical to utilize precedents that have already been set by local courts. For example, the reciprocal constitutionally protected interest of family members between children and parents and the idea that actions that “shock the conscience” of parents, children, or other minors in fulfilling their interests can be made to hold state actors liable. 

Wrongful incarcerations or deaths of family members caused by state actors can have irreplaceable effects on surviving family members which may be difficult to justify regardless of the specific intent. In these cases, the only remedy that empowers family members may be more judicial responsibility on the part of the state.

Image Source: Danny Burton