Santa Clara, Calif. police shoot, kill mentally ill woman who wielded a bat in her apartment. Her biological son and only living relative, who had been adopted by another family as an infant, sues the officers and the city. Ninth Circuit: Case dismissed. It’s not that children “adopted out” can never file Fourteenth Amendment loss of companionship claims on behalf of their biological parents. It’s that this plaintiff didn’t show he had enough of a relationship with his mother.