Aid for Women v. Foulston: 2nd Amended Complaint


Plaintiffs, by and through their undersigned attorneys, bring this complaint against the Defendants, their agents and successors in office, and in support thereof aver the following:

1. Plaintiffs are licensed professionals, including physicians, nurses, social workers, a psychologist, and a sexuality educator, who provide confidential health care and counseling services to adolescents in the state of Kansas. Plaintiffs fear that the Defendants and the members of the proposed defendant class will enforce the state’s child abuse reporting statute, Kan. Stat. Ann. § 38-1522 (“the reporting statute”), to require them to report their adolescent patients and clients to the state whenever plaintiffs suspect that those patients and clients have been sexually active, even if plaintiffs do not suspect that the sexual activity was "abuse" or injurious.