ARREY v. ZEBLEY

CourtDistrict Court, E.D. Pennsylvania
DecidedDecember 30, 2024
Docket2:24-cv-00589
StatusUnknown

This text of ARREY v. ZEBLEY (ARREY v. ZEBLEY) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ARREY v. ZEBLEY, (E.D. Pa. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

BRYANT OBEN ARREY : CIVIL ACTION : v. : No. 24-0589 : OFFICER JONATHAN ZEBLEY and : BROOKHAVEN POLICE : DEPARTMENT :

MEMORANDUM

Judge Juan R. Sánchez December 30, 2024 Pro se Plaintiff Bryant Oben Arrey brings this 42 U.S.C. § 1983 action against Defendants Police Officer Jonathan Zebley and the Brookhaven Police Department alleging various civil rights abuses pertaining to Arrey’s arrest on July 4, 2023 and its aftermath. Defendants seek to dismiss all but one of the claims in Arrey’s Amended Complaint for failure to state a claim. Because Arrey has not sufficiently plead the claims at issue, the Court will grant Defendants’ motion. BACKGROUND Plaintiff Bryant Oben Arrey, an Uber driver, alleges that around midnight on July 4, 2023, he was asleep in his car while parked on a deserted street in Delaware County. Amend. Compl. ¶¶ 10-11. Defendant Officer Jonathan Zebley and four other Brookhaven Police Department officers approached Arrey’s car and knocked on the window, asking Arrey what he was doing, to which Arrey explained he was sleeping because there were no requested Uber rides and the poor weather conditions made it unsafe to drive. Id. ¶¶ 12-13. Officer Zebley then asked to search Arrey’s vehicle and conduct a field sobriety test, to which Arrey consented. Id. ¶ 14. During the sobriety test, Zebley asked Arrey why his eyes were red and Arrey responded, “[T]hat’s how my eyes [are].” Id. ¶ 16. Zebley told Arrey he was under arrest for driving under the influence, and when Arrey asked why, Zebley explained that Arrey was parked six feet from the curb and he believed Arrey had “consumed something he is not sure of, but not alcohol.” Id. Following the arrest, Zebley took Arrey to a hospital for a blood draw and then to the police station for questioning and fingerprinting. Id. ¶ 17. Six weeks after the arrest, the blood test results came back negative for drugs and alcohol, which Arrey alleges “should have cleared defendant Jonathan Zebley’s suspicion.” Id. ¶ 19. Arrey alleges “defendant Jonathan still charged [him]” with driving under the influence, and subsequently, provided the court with false affidavits to mislead prosecutors. Id. ¶ 20-21. Arrey claims the false statements included: Officer Zebley found a substance resembling marijuana in

Arrey’s car, Arrey was parked 10 feet from the curb and blocking traffic, and Arrey has consumed a synthetic drug. Id. ¶ 22-24. At Arrey’s probable cause hearing, prosecutors decided “not to prosecute without further investigation.” Id. ¶ 25. The case was postponed until December 2023. Id. ¶ 26. At the December 2023 hearing, prosecutors sought to retest Arrey’s blood for synthetic drugs, informing Arrey that the charges would be dropped if no substance was found. Id. ¶ 26-27. The case was then postponed to January 2024. Id. ¶ 27. At the January 2024 hearing, prosecutors informed Arrey that all tests for synthetic drugs had come back negative, and that they were dropping the charges. Id. ¶ 28. Shortly before the hearing was about to begin, Officer Zebley requested a meeting with the prosecutor. Id. ¶ 29. Following the meeting, the prosecutor returned

to court and said, “I don’t know why the police department is bent on having this guy prosecuted.” Id. ¶ 30-31. The judge asked the prosecutor why he had changed his mind and called a meeting in chambers. Id. ¶ 33. The judge recused herself from the case and it was transferred to another county, where charges were later withdrawn. Id. On February 2, 2024, Arrey filed this pro se action against Zebley and the Brookhaven Police Department alleging various civil rights violations including false arrest and malicious prosecution (later filing an Amended Complaint on May 2, 2024). Defendants move to dismiss all but one of Arrey’s claims for failure to state a claim upon which relief may be granted. STANDARD To survive a motion to dismiss, a plaintiff must plead sufficient facts that when accepted as true, “state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A claim is facially plausible when it “allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. To make this determination, a reviewing court must (1) determine the elements required to plead each claim, (2) identify which allegations

are conclusory and may not be accepted as true, and (3) assess whether the remaining, non- conclusory allegations plausibly entitle the plaintiff to relief. Connelly v. Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016). Where a plaintiff is pro se, a court is to construe the allegations liberally, applying the “relevant legal principle even when the complaint has failed to name it.” Vogt v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021) (quoting Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 244-45 (3d Cir. 2013)). While this standard affords pro se litigants some flexibility, they must still allege sufficient facts to support their claims. Vogt, 8 F.4th at 185. Courts are not tasked with acting “as an advocate to identify any possible claim that the facts alleged could potentially support.” Doe v. Allegheny

Cnty. Hous. Auth., Civ. No. 23-1105, 2024 WL 379959, at *3 (3d Cir. Feb. 1, 2024). DISCUSSION In their motion, Defendants assert multiple deficiencies in Arrey’s Amended Complaint that warrant dismissal of all claims except Arrey’s Fourth Amendment claim for false arrest against Officer Zebley in his individual capacity. The Court agrees with Defendants’ arguments and addresses each in turn.1 I. Claims against the Brookhaven Police Department Defendants seek to dismiss the Brookhaven Police Department as a defendant, arguing the department is not a proper defendant because it is “simply a subdivision of its municipality.” ECF No. 14 at 7. Because the Brookhaven Police Department is not a proper defendant, the Court will dismiss it as a defendant. To bring a § 1983 suit against a municipal agency, a plaintiff must name the municipality itself. Sorrells v. Philadelphia Police Dep’t, 652 F. App’x 81, 83 (3d Cir. 2016)

(citing Bonenberger v. Plymouth Twp., 132 F.3d 20, 25 n.4 (3d Cir. 1997). For this reason, parties may not separately sue governmental sub-units, such as police departments. Moore v. Montgomery Cnty. Dist. Att’y Off., Civ. No. 22-2642, 2023 WL 5972045, at *2 (3d Cir. Sept. 14, 2023); Bonenberger, 132 F.3d at 25 n.4 (courts are to view the municipality and its police department as a “single entity for purposes of section 1983 liability”). In this action, Arrey has sued the Brookhaven Police Department—a subdivision of Brookhaven Borough—without naming the Borough itself. While Arrey previously sued the “Municipality of Brookhaven,” he voluntarily dismissed that defendant on February 29, 2024. See ECF No. 7. As a subdivision of the Borough, the Brookhaven Police Department cannot be sued

1 In addition to the specific claims described below, the Court will also dismiss Count I as duplicative of Arrey’s other claims. In Count I, Arrey claims “damages under § 1983 for the injuries set forth. . . against Defendants Jonathan Zebley and Brookhaven Police for violation of my constitutional rights under color of law.” Amend. Compl. ¶ 35. These allegations duplicate those made elsewhere in the Amended Complaint, albeit with less specificity. Because these claims can be consolidated with the more specific allegations elsewhere, Count I will be dismissed. See Telford Borough Auth. v. U.S.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Betts v. New Castle Youth Development Center
621 F.3d 249 (Third Circuit, 2010)
Gallo v. City of Philadelphia
161 F.3d 217 (Third Circuit, 1998)
Kelley Mala v. Crown Bay Marina
704 F.3d 239 (Third Circuit, 2013)
Randy Mulholland v. Government County of Berks
706 F.3d 227 (Third Circuit, 2013)
McTernan v. City of York, Pa.
564 F.3d 636 (Third Circuit, 2009)
Giannone v. Ayne Institute
290 F. Supp. 2d 553 (E.D. Pennsylvania, 2003)
Lawrence Thomas v. Cumberland County
749 F.3d 217 (Third Circuit, 2014)
Byron Halsey v. Frank Pfeiffer
750 F.3d 273 (Third Circuit, 2014)
DiBella v. Borough of Beachwood
407 F.3d 599 (Third Circuit, 2005)
Corliss v. O'Brien
200 F. App'x 80 (Third Circuit, 2006)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
OC Sorrells v. Philadelphia Police Department
652 F. App'x 81 (Third Circuit, 2016)
Michele Black v. County of Montgomery
835 F.3d 358 (Third Circuit, 2016)
Manuel v. City of Joliet
580 U.S. 357 (Supreme Court, 2017)
Estate of Adriano Roman, Jr. v. City of Newark
914 F.3d 789 (Third Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
ARREY v. ZEBLEY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arrey-v-zebley-paed-2024.