CARROLL v. MCCANN

CourtDistrict Court, E.D. Pennsylvania
DecidedSeptember 19, 2025
Docket5:25-cv-04985
StatusUnknown

This text of CARROLL v. MCCANN (CARROLL v. MCCANN) 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
CARROLL v. MCCANN, (E.D. Pa. 2025).

Opinion

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

ARTIC C. CARROLL, JR. : CIVIL ACTION : v. : NO. 25-4985 : LUKE MCCANN, et al.

MEMORANDUM KEARNEY, J. September 19, 2025 Police arrested a man for indecent exposure and other crimes at a Delaware County shelter in November 2021. They placed him in custody. The police released him. The state court set a date for him to return for his hearing under a bench warrant. He failed to show. The state court ordered his arrest and placed him in custody the next day for failing to appear in court. He remained in custody while pro se litigating his competence for over a year. The Commonwealth eventually released him in August 2023 after dismissing the charges. He is now out of custody and—for the tenth time in this Court—sues those who he thinks violated his rights in Delaware County. We screened his pro se allegations after granting him leave to proceed without paying the filing fees. We today again dismiss his claims with prejudice as to all allegations against the judges, prosecutors, defenders, and entities not persons subject to civil rights liability. We also dismiss with prejudice his false arrest and false imprisonment claims and his claims under the First, Fourth, Fifth, and Sixth Amendments. We decline to exercise supplemental jurisdiction absent a pleaded federal question. But we allow the serial litigant one more chance to plead claims within our limited jurisdiction as to his Fourteenth Amendment claim, civil conspiracy claim, claims asserted against Delaware County, Delaware County Jail Oversight Board, the GEO Group, and Upper Darby Township for an unconstitutional policy or custom allegedly causing constitutional harm, claims asserted against the Life Center for Eastern Delaware County and the Community Action Agency of Delaware County, and individual capacity claims against John Swider, Oscar Lemus- Rojas, Tyrance Moore, Devon Anne Rink, Stephanie French, Shawnell George, Intake Counselor Michael Moore, Upper Darby Mayor Ed Brown, Upper Darby Police Chief Timothy Bernhardt, Upper Darby Police Deputy Chief Cory Cooper, unnamed Life Center for Eastern Delaware

County counselors, and unnamed Community Action Agency of Delaware County officials if he can do so consistent with his obligations of good faith pleading grounded in federal law and not already dismissed. I. Alleged pro se facts and matters of public record Artis C. Carroll, Jr. moved into the Life Center of Eastern Delaware County emergency shelter in September 2021.1 He allegedly exposed himself to a shelter volunteer with whom he worked on November 4, 2021. The volunteer called 911 to report the incident. Upper Darby Police Officer Luke McCann responded to the call.2 The volunteer identified Mr. Carroll as the individual involved.3 Mr. Carroll told Officer McCann he had asked the volunteer for help with a botched circumcision.4 Officer McCann arrested Mr. Carroll and transported him to the Upper Darby Police

Station.5 Police charged him with indecent exposure, open lewdness, disorderly conduct, and harassment.6 A magistrate judge set bail at $25,000 following a preliminary arraignment at the police station.7 Mr. Carroll could not pay bail and the police transported him to the George W. Hill Correctional Facility.8 Delaware County Public Defender Rebecca Richman represented Mr. Carroll at his preliminary hearing in mid-November 2021.9 Officer McCann did not appear and Public Defender Richman did not move to dismiss.10 Mr. Carroll corrected the record at the hearing because Public Defender Richman told the judge Mr. Carroll wanted to represent himself.11 Mr. Carroll pro se filed five motions shortly after the preliminary hearing.12 The Facility released Mr. Carroll from custody on December 1, 2021 after posting bail.13 But then he did not appear at a pretrial conference on January 31, 2022.14 Judge Mary Brennan revoked his bail and issued a bench warrant for his arrest.15 The Commonwealth arrested Mr. Carroll the following day and returned him to custody.16 Judge Gregory Mallon held a bench warrant hearing on February 3, 2022 and ordered a mandatory involuntary competency

examination as a condition of pre-trial release.17 Mr. Carroll did not consent.18 Delaware County Public Defender Timothy Walsh replaced Public Defender Richman as Mr. Carroll’s counsel.19 Public Defender Walsh told Mr. Carroll the court-ordered evaluation could not be challenged and repeatedly pressured him to submit.20 Public Defender Walsh filed a bail motion representing Mr. Carroll agreed to a competency exam in exchange for unsecured bail.21 Public defenders and prosecutors requested multiple continuances over the following months based on Mr. Carroll’s refusal to submit to the evaluation.22 Judge Brennan did not rule on Mr. Carroll’s objections and denied his request for conflict counsel to argue his competency.23 Mr. Carroll filed at least forty-five pro se motions and other filings, including several interlocutory

appeals and a petition for a writ of certiorari, between February 2022 and his release in August 2023.24 The Commonwealth declined to prosecute the underlying November 2021 arrest relating to his alleged indecent exposure at the shelter on August 24, 2023 and released Mr. Carroll from custody.25 II. Analysis Serial litigant Artis C. Carroll, Jr. again sues many of the same state officials and entities he sued before in connection with his November 2021 arrest for indecent exposure to a shelter volunteer and subsequent detention for failing to appear under a bench warrant. 26 He pro se sues more than forty state actors, local institutions, and county officials for a wide-ranging civil rights conspiracy and unlawful arrest and pretrial detainment. He asserts claims these same persons violated his civil rights, the Due Process Clause of the Fourteenth Amendment, the Pennsylvania Constitution, and various state laws.27 He claims these entities and individuals violated his First, Fourth, Fifth, Sixth, and Fourteenth Amendment rights through his unlawful arrest and pretrial

detention.28 He alleges the Upper Darby Police Department maintained a policy or custom of making arrests without probable cause and failing to train officers on constitutional requirements.29 He further alleges police, prison officials, county actors, judges, public defenders, prosecutors, and staff from the Life Center for Eastern Delaware Couty and Community Action Agency of Delaware County coordinated a conspiracy to arrest him and deliberately orchestrated and concealed a plan to detain him on fabricated charges.30 Mr. Carroll asserts the GEO Group, Delaware County, and the Delaware County Jail Oversight Board maintained policies and practices at the Facility which lacked adequate release-tracking systems, failed to train or supervise staff, and enabled his continued confinement without lawful basis.31 He seeks compensatory,

punitive, and statutory damages, as well as declaratory and injunctive relief aimed at reforming detention practices, arrest procedures, and oversight systems within Upper Darby, the Facility, and related agencies.32 He again proceeds without paying the filing fees. Congress requires we screen Mr. Carroll’s case now proceeding without paying filing fees before issuing summons.33 We must dismiss this Complaint before issuing summons if we find Mr. Carroll’s claims are frivolous or malicious, do not state a claim on which relief may be granted, or he seeks monetary relief against immune persons.34 We apply the same standard under the Federal Rule of Civil Procedure 12(b)(6) when considering whether to dismiss a complaint under section 1915(e)(2)(B)(ii).35 Mr.

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CARROLL v. MCCANN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carroll-v-mccann-paed-2025.