Pre-Suspension Notice and Opportunity to Contest Suffice for Florida Child-Support-Related License Suspensions; Qualified Immunity Bars § 1983 Claims Against the Program Director

Case: Kenneth Parson, Jr. v. Ann Coffin (11th Cir. Jan. 2, 2026) (per curiam) (Not for Publication)
Posture: Appeal from dismissal (without leave to amend) of a pro se 42 U.S.C. § 1983 amended complaint.

1. Introduction

This appeal arose from Florida’s child-support/paternity enforcement framework, under which the Florida Department of Revenue (“DOR”) Child Support Program may pursue administrative paternity proceedings and, if a respondent fails to submit to ordered genetic testing, initiate steps leading to suspension of the respondent’s driver’s license and motor vehicle registration.

Parties. Plaintiff-Appellant Kenneth R. Parson, Jr. (pro se) sued Defendant-Appellee Ann Coffin, alleged to be the Director of the DOR Child Support Program, in her individual capacity.

Key issues. (1) Whether Parson plausibly alleged a procedural due process violation under the Fourteenth Amendment and § 1983 based on license/registration suspension allegedly without adequate notice or hearing; (2) whether Coffin was entitled to qualified immunity; and (3) whether the court should have granted leave to amend.

The Eleventh Circuit decided the case on a motion-to-dismiss record, emphasizing that attached exhibits control over contradictory allegations and that due process in this setting is evaluated under the Mathews v. Eldridge balancing framework as applied to license deprivations.

2. Summary of the Opinion

The Eleventh Circuit affirmed dismissal without leave to amend. It held that Parson failed to state a procedural due process claim because the documents attached to his complaint showed he received pre-suspension notice and avenues to contest the action (including petitioning in circuit court and requesting a hearing). The court further held that, even if a claim had been stated, Coffin was entitled to qualified immunity because her alleged conduct fell within discretionary authority and did not violate clearly established law. Finally, the court upheld denial of leave to amend as futile given qualified immunity.

3. Analysis

3.1. Precedents Cited

Hunt v. Aimco Properties, L.P. — Used for the Rule 12(b)(6) pleading standard: on de novo review, allegations are accepted as true and construed favorably to the plaintiff, but must still plausibly state a claim.
Fed. R. Civ. P. 10(c) and Griffin Indus., Inc. v. Irvin — Central to the court’s treatment of Parson’s exhibits: because the suspension notices were attached to the pleading, they were “part of the pleading for all purposes,” and where exhibits contradict conclusory allegations, “the exhibits govern.” This significantly narrowed Parson’s ability to allege “no notice/no hearing.”
Grayden v. Rhodes — Provided the Eleventh Circuit’s elements for a procedural due process claim and reiterated the constitutional “minimum” of notice and an opportunity to be heard.
Mathews v. Eldridge — Supplied the balancing test for procedural adequacy. The opinion treats Mathews as the governing framework for assessing whether the combination of notice plus an opportunity to contest (not necessarily a pre-deprivation evidentiary hearing) satisfies due process.
Dixon v. Love — The pivotal Supreme Court analogue. The court relied on Dixon’s application of Mathews to driver’s license deprivations to support the proposition that something less than a pre-suspension evidentiary hearing can satisfy due process, especially where decisions are largely automatic and subject to review.
Cottone v. Jenne — Anchored the qualified-immunity framework at the pleading stage, including that dismissal is appropriate when the face of the complaint shows an affirmative defense bars recovery and that the plaintiff must show a violation of clearly established law once qualified immunity is raised.
Chang v. JPMorgan Chase Bank, N.A. — Framed review of denial of leave to amend (abuse of discretion) and the de novo review of the legal conclusion of futility.
Evans v. Ga. Reg'l Hosp. (abrogated on other grounds by Bostock v. Clayton Cnty., Ga.) — Supplied the pro se amendment principle (ordinarily at least one chance to amend) and the futility exception, which the court applied to uphold dismissal without further leave.

3.2. Legal Reasoning

(a) Procedural due process and the controlling effect of exhibits. Although Parson alleged that Coffin suspended his license and registration “without notice” and “without a hearing,” the court treated the attached notices as dispositive under Fed. R. Civ. P. 10(c) and Griffin Indus., Inc. v. Irvin. Those notices stated:

DOR’s “Notice of Intent to Suspend” warned of suspension due to failure to submit to genetic testing and informed Parson he could schedule testing or “[c]ontest this action by filing a petition in circuit court.”
FLHSMV’s notice provided the effective suspension date, steps to “clear” the issue, and the ability to request a hearing “to present evidence per section 322.271, Florida Statutes.”

Those documents undermined the central factual predicate of Parson’s due process theory.

(b) Mathews balancing in the license-suspension context. Applying Mathews v. Eldridge, as illuminated by Dixon v. Love, the court reasoned:

Private interest: A driver’s license is a property interest implicating due process (Dixon v. Love), but the Supreme Court has recognized it is not invariably so “vital and essential” as to require a pre-deprivation evidentiary hearing in all administrative suspensions.
Risk of erroneous deprivation / value of extra safeguards: The suspension followed an alleged failure to comply with a genetic testing order and was accompanied by mechanisms to contest the action. In the court’s view, this reduced the risk of error in a way comparable to the “automatic” or low-discretion features emphasized in Dixon v. Love.
Government interest: The government’s interest in enforcing participation in paternity proceedings (and the associated administrative efficiency) weighed against adding more procedural layers.

On these facts, the court concluded Parson did not plausibly allege “constitutionally inadequate process,” an essential element under Grayden v. Rhodes.

(c) Personal involvement and plausibility as to Coffin. The court also noted Parson did not plausibly allege Coffin personally took action to suspend his license, and the exhibits did not show her “signed off” on the suspension. While the opinion ultimately focuses on adequacy of process (and qualified immunity), this observation underscores an additional plausibility gap: § 1983 liability requires a link between the defendant’s acts and the alleged deprivation.

(d) Qualified immunity at the motion-to-dismiss stage. Under Cottone v. Jenne, once qualified immunity is raised, Parson had to allege a violation of clearly established law. The court held:

Coffin (as Director) would have been acting within discretionary authority when initiating the statutory process referenced in Fla. Stat. §§ 409.256, 61.13016, and related provisions.
No clearly established federal right required a court order before the license suspension in these circumstances, particularly where notice and opportunities to contest existed.

Thus, even if Parson had stated a due process claim, qualified immunity independently barred damages claims against Coffin in her individual capacity.

(e) Leave to amend and futility for pro se litigants. Relying on Evans v. Ga. Reg'l Hosp. (and the futility exception), the court held denial of leave to amend was not an abuse of discretion because any amendment would be futile in light of qualified immunity. The court reviewed the futility conclusion consistent with Chang v. JPMorgan Chase Bank, N.A..

3.3. Impact

Although unpublished (“NOT FOR PUBLICATION”) and therefore not intended to create binding circuit precedent, the decision is instructive in three practical ways:

Due process challenges to administrative license suspensions: Plaintiffs will face an uphill climb where the state provides pre-suspension notice and defined avenues to contest (even if the initial action is administrative), because Mathews v. Eldridge as applied in Dixon v. Love tolerates streamlined procedures for driver’s license deprivations.
Pleading strategy and exhibits: Attaching notices and agency documents can defeat “no notice/no hearing” allegations at the pleading stage; courts may treat the exhibits as controlling under Griffin Indus., Inc. v. Irvin.
Qualified immunity as an early gatekeeper: When statutory authority exists and notices reflect available review mechanisms, qualified immunity may render amendment futile, supporting dismissal without further leave even for pro se plaintiffs under Evans v. Ga. Reg'l Hosp..

4. Complex Concepts Simplified

Procedural due process: The Constitution generally requires the government to provide notice and an opportunity to be heard before (or sometimes soon after) taking away a protected interest like a driver’s license.
Mathews v. Eldridge balancing: Courts weigh (1) how important the individual interest is, (2) how likely the process is to make mistakes and whether extra steps would help, and (3) the government’s interest and burdens of additional procedures.
Qualified immunity: Even if a plaintiff alleges wrongdoing, an official sued personally is typically not liable for damages unless the plaintiff shows the official violated a right that was “clearly established” at the time (i.e., existing law made the unlawfulness obvious).
“Exhibits govern” (Rule 10(c)): If a complaint’s attached documents contradict broad allegations, a court can rely on the documents rather than the conclusory statements when deciding a motion to dismiss.
Futility of amendment: Courts need not allow another amended complaint when the legal barrier (here, qualified immunity as applied to the alleged conduct and the documented process) would still require dismissal.

5. Conclusion

The Eleventh Circuit affirmed dismissal of Parson’s § 1983 due process suit challenging a child-support/paternity-related license suspension process. The opinion’s core lessons are that (1) pre-suspension notice coupled with accessible mechanisms to contest or obtain a hearing can satisfy procedural due process under Mathews v. Eldridge and Dixon v. Love; (2) complaint exhibits can defeat conclusory allegations at the pleading stage; and (3) qualified immunity can foreclose damages claims—and render further amendment futile—when the official’s conduct aligns with statutory authority and does not violate clearly established law.