Bristol Oak Properties, Inc. v. Commonwealth of Pennsylvania, et al.

CourtDistrict Court, E.D. Pennsylvania
DecidedNovember 26, 2025
Docket2:25-cv-00504
StatusUnknown

This text of Bristol Oak Properties, Inc. v. Commonwealth of Pennsylvania, et al. (Bristol Oak Properties, Inc. v. Commonwealth of Pennsylvania, et al.) 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
Bristol Oak Properties, Inc. v. Commonwealth of Pennsylvania, et al., (E.D. Pa. 2025).

Opinion

IN THE UNITED STAES DISTRICT COURT FOR THE EASTER DISTRICT OF PENNSYLVANIA

BRISTOL OAK PROPERTIES, INC., : Plaintiff, : No. 25-cv-0504-JMY : vs. : : COMMONWEALTH OF : PENNSYLVANIA, et al., : Defendants. :

MEMORANDUM Younge, J. November 26, 2025 Currently before the Court is a Motion to Dismiss for Failure to State a Claim and for Lack of Subject Matter Jurisdiction filed by Defendants, the Commonwealth of Pennsylvania, Pennsylvania Department of Transportation, and Michael Carrol (hereinafter the “Commonwealth Defendants”). (Commonwealth Defendants’ Motion to Dismiss, ECF No. 14.) Defendants, Bensalem Township and Kenneth V. Farrall, as the Director of Building and Planning and the Zoning Officer for Bensalem Township (hereinafter the “Bensalem Defendants”), have also filed a Motion to Strike and Dismiss Plaintiff’s Amended Complaint under Fed. R. Civ. P. 12(b)(6). (Bensalem Defendants’ Motion to Strike and Dismiss Plaintiff’s Amended Complaint under Fed. R. Civ. P. 12(b)(6), ECF No. 16.) The Court finds Defendants’ Motions appropriate for resolution without oral argument. Fed. R. Civ. P. 78; L.R. 7.1(f). For the reasons set forth in this Memorandum, Defendants’ Motions will be granted, and all claims asserted in the Amended Complaint will be dismissed with prejudice and without leave to amend. I. FACTUAL AND PROCEDURAL BACKGROUND: A. Procedural History: Plaintiff, Bristol Oak Properties, Inc., brings this lawsuit against Defendants: the Commonwealth of Pennsylvania (the “Commonwealth”); Michael Carrol, the Secretary of the Pennsylvania Department of Transportation (“Carrol”); the Pennsylvania Department of

Transportation (“PennDOT”); Bensalem Township; and Kenneth V. Farrall, the Director of Building and Planning and Zoning Officer for Bensalem Township (“Farrall”). (Amended Complaint ¶¶ 5-9, ECF No. 10.) In this lawsuit, Plaintiff alleges that it owned two parcels of real property in Bensalem Township, Pennsylvania which it sold prior to filing this lawsuit. (Id. ¶¶ 2, 13, 39.) Plaintiff further alleges that Defendants violated the fourth, fifth and Fourteenth Amendments to the United States Constitution when Defendants refused to maintain infrastructure in the form of a stormwater drainage system running along Bristol Road. (Id.) In the Amended Complaint, Plaintiff sues Defendants based on five separate legal theories as follows: (1) Plaintiff asserts claims for malicious prosecution under Section 1983 (Id.

(Count I); (2) Plaintiff alleges that Defendants violated the Equal Protection Clause and the Due Process Clause of the United States Constitution (Id. (Count II); (3) Plaintiff alleges that Defendants violated its Procedural Due Process Rights under Section 1983 and Section 1985 (Id. (Count III); (4) Plaintiff alleges that Defendants failed to maintain the stormwater system in accordance with law and regulation under 1983 (Id. (Count IV); and (5) Plaintiff asserts state law legal theories of negligence and tortious interference. (Id. (Count V).) The Commonwealth Defendants now move to dismiss for lack of subject matter jurisdiction under Fed. R. Civ. P. 12(b)(1) and failure to state a claim under Fed. R. Civ. P. 12(b)(6). (The Commonwealth Defendants’ Motion to Dismiss.) The Bensalem Defendants have also filed a motion to dismiss for failure to state a claim under Fed. R. Civ. P. 12(b)(6). (Bensalem Defendants’ Motion to Dismiss.) B. Factual Background: Plaintiff owned two properties in Bensalem Township, Pennsylvania located at 4550 Bristol Road and 4432 Bristol Road, Bensalem Township, Bucks County, Pennsylvania which it

sold prior to instituting this lawsuit. (Id. ¶ 13, 39.) Plaintiff alleges that between approximately 1975 and 1985, PennDOT installed a stormwater management system below the surface of Bristol Road, also known as State Route 2025. (Id. ¶ 17.) Plaintiff claims that over the years, despite occasional maintenance, PennDOT allowed the stormwater system’s condition to deteriorate. (Id. ¶ 20.) Plaintiff further alleges that the Commonwealth Defendants were responsible for maintaining the stormwater management system which included the responsibility to ensure proper drainage to prevent unsafe water accumulation on Bristol Road. (Id. ¶ 14, 16.) In support of its contention that the Commonwealth Defendants were responsible for stormwater management, Plaintiff specifically avers that between the years of 1975 through

1985 and again in 2010 and 2011, the Commonwealth Defendants along with the Bensalem Defendants installed, repaired and maintained the stormwater management system as if it was within their right-of-way. (Id. ¶¶ 17-18.) The Amended Complaint depicts a saga that took place over the course of more than a decade in which Defendants are alleged to have attempted to thwart and duck responsibility for the stormwater management system and related flooding along Bristol Road. According to the narrative depicted in the Amended Complaint, Plaintiff became entangled in a bitter dispute with Defendants over who was responsible for maintaining the stormwater management system that ran adjacent to Bristol Road along the two properties. Plaintiff alleges that Defendants wrongfully took the position that maintenance on the stormwater system was Plaintiff’s responsibility while Plaintiff maintains that Defendants were responsible for maintenance of the system. Plaintiff avers that beginning on October 4, 2011, Defendant Bensalem Township issued a Notice of Violation to Plaintiff directing Plaintiff to repair damage on the property at issue that

was related to the stormwater management system. (Id. ¶ 23.) On December 15, 2011, the Bensalem Township Defendants cited Plaintiff with two Summary Offenses for failure to cure the conditions of the stormwater management system identified in the Notice of Violation issued on October 4, 2011. Plaintiff allegedly challenged the two Summary Offenses by arguing that repair and maintenance of the stormwater management system was the responsibility of the Commonwealth Defendants rather than itself. (Id.) Plaintiff further asserts that it ultimately prevailed in its position and that the court dismissed Summary Offenses by finding that the Commonwealth Defendants were responsible for repair and maintenance of the stormwater system. After the court dismissed Summary Offenses, Plaintiff avers that PennDot made repairs

to the damaged stormwater management system at 4550 and 4432 Bristol Road. (Id. ¶¶ 25, 26.) Plaintiff claims that the condition of the stormwater management system continued to deteriorate and was at risk of failure by late 2022; however, Defendants continued to deny responsibility. (Id. ¶¶ 28.) Instead, the Bensalem Defendants issued another Summary Offense to Plaintiff on September 6, 2022, instructing Plaintiff to “repair all parking and asphalted areas of the property so that there [were] no longer any potholes, ruts, or other erosion issues on the property.” (Id. ¶ 30.) Plaintiff claims he contacted the Bensalem Defendants to assert that Defendants were responsible for maintenance. (Id. ¶ 32.) Thereafter, the Bensalem Defendants agreed to drop the Summary Offenses but allegedly continued to deny responsibility for the stormwater management system. (Id.

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Bristol Oak Properties, Inc. v. Commonwealth of Pennsylvania, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/bristol-oak-properties-inc-v-commonwealth-of-pennsylvania-et-al-paed-2025.