Doe

BACKGROUND

19 A. Allegations in the SAC. Plaintiffs Jane and Jill Doe (“Plaintiffs”) were minor children at all relevant times. (Dkt. 21 No. 61, SAC, ¶ 3.) The Santa Clara Department of Family and Children’s Services (“DFCS”) 22 removed Plaintiffs from their parents’ care due to alleged substance abuse and domestic violence 23 issues. (Id. ¶ 11.) 24 Jane, the older sister, was removed before Jill’s birth. At the time of her removal, Jane had 25 a close personal relationship with her maternal grandmother. (Id.) Jane’s grandmother frequently 26 27 acted as her caregiver. (Id.) Nevertheless, DCFS declined to consider placing Jane with her grandmother due to the grandmother’s criminal history and poor relationship with Jane’s mother. (Id. ¶ 14.) DCFS also declined to place Jane with her maternal great-grandparents, because Jane’s mother abused her on their property. (Id. ¶ 13.) Finally, DCFS declined to place Jane with a maternal cousin because she lived outside of Santa Clara County. (Id. ¶ 15.) DCFS instead placed Jane with Brian Hernandez and Marissa Clark. (Id. ¶ 16.) Hernandez and Clark were licensed foster parents residing…