Doe v. the Governor

The plaintiffs seek declaratory and injunc-tive relief to remedy deficiencies in the Commonwealth’s system of protective services for abused and neglected children, which is alleged to be “in a state of complete chaos and total disarray.” We hold that their complaint is defective in its failure to allege any specific grievance, but that they should be given a further opportunity to amend the complaint. We defer consideration of other contentions.

The complaint as originally filed in September, 1979, described the plaintiffs as “the abused and neglected children of the Commonwealth of…