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CORTLAND, N.Y. — A judge ruled that two motions to dismiss complaints filed in a case involving the death of a 4-year-old shall be denied.

The complaints are against the attorney for 4-year-old Rykelan Brown, Lenore LeFevre, and the Cortland County Department of Social Services. They were filed in Cortland County Court by Brown’s foster parent, Samantha Adams, who claimed that LeFevre and the DSS did not do enough to protect Brown before he was killed by his father, Joshua Emmons.

In their motion to dismiss, LeFevre and the DSS argued they had immunity in the case.

However, Judge Mark G. Masler refuted this. Judge Masler denied LeFevre’s motion on the basis that she failed to meet professional standards as the representative of Brown. He denied the DSS motion on the basis that it had failed to investigate Emmons’s “fitness” to serve as the custodial parent of Brown.

Masler’s decisions were made on June 4.

In May 2024, just two months after the DSS put Rykelan in Emmons’ custody, he was brought to the hospital with severe injuries. He died three days later on May 29. His death was determined as a subdural hematoma caused by being shaken, struck or slammed into another object. Emmons was arrested in July 2024 by deputies with the Onondaga County Sheriff’s Office.

On Sept. 16, 2025, Emmons was sentenced to 25-years-to life in prison after pleading guilty to manslaughter.

Adams cared for Brown for most of his life. On the day of Emmon’s sentencing, she said that Brown made her a mother and she loved him dearly.