Donald v. Polk County
In Donald v. Polk County, 836 F.2d 376 (7th Cir.1988), the parents of a child removed from their home sued various state officials alleging a violation of their due process and familial relations rights.
The Court held that the Donalds' claims were precluded by the doctrine of collateral estoppel because a jury concluded by clear and convincing evidence that their daughter had been physically abused. Id. at 382.
However, in that case the Donalds did not claim they were not afforded full discovery rights, nor did they cite any "specific instances of a false statement or even an exaggerated statement in any of the defendants' reports, petitions, or testimony." Id. at 381.
The Donalds also did not propose any "reasonable motive why the defendants would be prejudiced against the Donalds." Id.
Based on these circumstances, the Court concluded the conclusory allegations of bad faith on the part of the defendants prevented the Donalds from relying on a claim of fraud in the underlying custodial hearing to overcome the doctrine of collateral estoppel.