Suter v. Artist M

Suter v. Artist M. (503 U.S. 347 [1992]) centered on a provision of the Adoption Assistance and Child Welfare Act of 1980 requiring State plans to provide that reasonable efforts be made to prevent removal of children from their homes prior to foster care placement. The Court ruled that the "reasonable efforts" provision was too vague to be enforceable under section 1983, as there was "no further statutory guidance ... as to how 'reasonable efforts' are to be measured." ( Id., at 360.) Further, the Court suggested that the plaintiffs' argument was undermined by the fact that the statute did not directly require the State to use reasonable efforts, but merely to file a plan providing that such efforts would be made. ( Id., at 358-359.)