What is the test for a parent to make a substantive due process claim against the state for interfering with the welfare of their child?

"It is well established that a parent has a fundamental liberty interest in the companionship and society of his or her child and that the state's interference with that liberty interest without due process of law is remediable under 42 U.S.C. 1983." Lee v. City of L.A., 250 F.3d 668, 685 (9th Cir. 2001) (internal citations, quotations, and alterations omitted).³ To prevail on such a substantive due process claim requires a parent demonstrate the liberty deprivation was caused by the government "in such a way that shocks the conscience or interferes with rights implicit in the concept of ordered liberty."

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