plaintiffs fail to state a claim against Scheer with respect to their allegation that Scheer had no probable cause to initiate child custody proceedings because Scheer did not violate a clearly established substantive due process right held by plaintiffs. However, plaintiffs also allege that Scheer misrepresented Dr. Henretig’s medical report, induced CHOP to falsify records and attempted to suborn perjury. These allegations when applied to taking children from their parents would by anyone’s definition be patently unlawful and a clearly established substantive due process violation. Consequently, plaintiffs have alleged conduct that is not deserving of qualified immunity and defendants’ motion to dismiss is denied with respect to these claims. See Fanning, 702 F.Supp. at 1190 (<HOLDING>). Malicious Prosecution Plaintiffs assert the
holding a police chase of a fleeing suspect that resulted in a fatal accident may support a substantive due process claim based on the theory that the officers conduct constituted arbitrary government action shocking the judicial conscience holding that plaintiff must allege conduct so arbitrary and unreasonable that it shocks the conscience in order to state substantive due process claim in context of social workers alleged interference with parents custody rights holding forcible extraction of the contents of defendants stomach shocks the conscience and violates due process recognizing  1983 substantive due process claim holding forced stomach pumping shocks the conscience and violates substantive due process