in Valdivieso Ortiz, 807 F.2d 6, the First Circuit was unclear about whether it had based its denial of a familial association claim on the lack of specific intent or the fact that the child at issue was an adult, in subsequent cases the First Circuit has clarified that even in cases involving minor children, specific intent is required. See Soto v. Flores, 103 F.3d 1056, 1062 (1st Cir.1997) (citing Ortiz as requiring specific intent, and dismissing familial association claim as to minor children); Manarite ex rel. Manarite v. City of Springfield, 957 F.2d 953, 960 (1st Cir.1992) (citing Ortiz as requiring specific intent). One circuit, the Eleventh Circuit, has stated in dicta that specific intent is necessary. See Robertson v. Hecksel, 420 F.3d 1254, 1259, 1260 n. 5 (11th Cir.2005) (<HOLDING>). One circuit, the Ninth Circuit, has
holding that a mother successfully stated a violation of the fourteenth amendment by alleging that the los angeles police department recklessly deprived her of the companionship of her mentally disabled adult son holding that negligence does not violate the due process clause but reserving the question whether gross negligence does holding that a mother and her two children failed to establish a  1983 claim where there was no evidence that threats made to the mother were directly aimed at the relationship between parent and child holding that a parentchild relationship between two independent adults does not invoke constitutional companionship interests and noting in dicta that even if it were to hold that right existed mere negligence does not implicate the due process clause and the mother had not alleged that the officer who shot her adult son acted with more than negligence concerning her rights holding that mere negligence does not implicate the right to due process