Katherine Powers v. Office of Child Support

Summary

The court affirmed dismissal of Powers's claims arising from OCS's allegedly inadequate child-support enforcement, concluding that OCS's functions were uniquely governmental and lacked a private analog, so sovereign immunity barred claims against the State and OCS. The individual employees could not be liable because OCS owed Powers no specific duty and the complaint alleged, at most, incompetence and clerical errors rather than gross negligence or willful misconduct. The court also held that the purported contract and file-access claims were encompassed by the same immunities or were not supported by an actual contract.