CONKLIN v. ALLEGHENY COUNTY

CourtDistrict Court, W.D. Pennsylvania
DecidedMarch 20, 2025
Docket2:23-cv-01987
StatusUnknown

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

Bluebook
CONKLIN v. ALLEGHENY COUNTY, (W.D. Pa. 2025).

Opinion

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

GERALD CONKLIN, ) ) CIVIL ACTION NO. 23-1987 Plaintiff, ) ) v. ) ) ALLEGHENY COUNTY, ) ) Defendant. ) ) MEMORANDUM OPINION I. Introduction This case was referred to a United States Magistrate Judge for pretrial proceedings in accordance with the Magistrate Judges Act, 28 U.S.C. § 636(b)(1), and Local Rules of Court 72.C and 72.D. On February 14, 2025, the magistrate judge issued a Report and Recommendation (“R&R”) (ECF No. 33), which recommended that the motion to dismiss filed by defendant Allegheny County (the “County” or “defendant”) (ECF No. 23) the second amended complaint (“SAC”) (ECF No. 19) filed on behalf of plaintiff Gerald Conklin (“Conklin” or “plaintiff”) be granted. Conklin filed timely objections to the R&R (ECF No. 36), with brief in support (ECF No. 37). The objections will be resolved without a response from Defendant. II. Standard of Review Pursuant to 28 U.S.C. § 636(b) and Federal Rule of Civil Procedure 72, the district court “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made” and “may also receive further evidence or recommit the matter to the magistrate judge with instructions.” 28 U.S.C. § 636(b)(1)(C). Rule 72(b)(3) requires de novo review of any recommendation that is dispositive of a claim or defense of a party to which proper objections were made. See Fraunhofer- Gesellschaft Zur Forderung Der Angewandten Forschung E.V. v. Sirius XM Radio Inc., No. 1:17CV184, 2021 WL 1147010, at *1 (D. Del. Mar. 25, 2021).

Even if no objections are filed, the court should, as a matter of good practice, “satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.” Fed. R. Civ. P. 72(b), advisory committee notes; see McClain v. Pennsylvania Dep’t of Corr., No. 1:19-CV-1951, 2020 WL 1690081, at *1 (M.D. Pa. Apr. 7, 2020); Univac Dental Co. v. Dentsply Int’l, Inc., 702 F. Supp. 2d 465, 469 (M.D. Pa. 2010) (explaining that judges should review dispositive legal issues raised by the R&R for clear error). III. Rule 12(b)(6) Standard of Review The Federal Rules of Civil Procedure govern motions to dismiss. Specifically, Rule 12(b)(6) provides for a motion to dismiss for failure to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). Rule 12(b)(6) works in conjunction with Rule 8, which requires

that a claim for relief contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). For a complaint to withstand a motion to dismiss, it must contain enough 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) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). To be considered facially plausible, the facts of the claim must allow a court reasonably to infer that the defendant is liable for the alleged wrongdoing. Id. In addition to accepting the factual allegations as true, the court must also view those facts “in the light most favorable to the non-moving

2 party.” Doe v. Univ. of Scis., 961 F.3d 203, 208 (3d Cir. 2020). Following Twombly and Iqbal, “it is clear that conclusory or ‘bare-bones’ allegations will no longer survive a motion to dismiss[]” because ‘“threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.’” Fowler v. UPMC

Shadyside, 578 F.3d 203, 210 (3d Cir. 2009) (quoting Iqbal, 556 U.S. at 678). Likewise, “the court need not accept as true ‘unsupported conclusions and unwarranted inferences,’ or the plaintiff’s ‘bald assertions’ or ‘legal conclusions.’” Cook v. W. Homestead Police Dep't, No. 2:16-CV-01292, 2017 WL 1550190, at *2 (W.D. Pa. May 1, 2017) (quoting Doug Grant, Inc. v. Great Bay Casino Corp., 232 F.3d 173, 183–84 (3d Cir. 2000) and Morse v. Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997)). The United States Court of Appeals for the Third Circuit laid out the following three-part process for a court to determine whether a complaint can survive a motion to dismiss: First, the court must “tak[e] note of the elements a plaintiff must plead to state a claim.” Second, the court should identify allegations that, “because they are no more than conclusions, are not entitled to the assumption of truth.” Finally, “where there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement for relief.”

Burtch v. Milberg Factors, Inc., 662 F.3d 212, 221 (3d Cir. 2011) (quoting Santiago v. Warminster Twp., 629 F.3d 121, 128 (3d Cir. 2010)).

IV. Discussion In the SAC, Conklin asserted claims based on both: (1) inadequate medical care; and (2) an alleged sexual assault by other inmates. The R&R recommended that the SAC be dismissed in its entirety. In the objections, Conklin challenges only the analysis with respect to medical 3 care. The court will review the objections about medical care de novo, and will undertake a “clear error” review with respect to the assault allegations. Conklin’s complaint spans three and a half years, from December 20, 2019, through May 10, 2023. During that period, Conklin was a pretrial detainee at the Allegheny County Jail

(“ACJ”). Although the SAC purports to assert claims under the Eighth Amendment, Conklin recognizes that as a pretrial detainee, his claims for inadequate medical care arise under the Due Process clause of the Fourteenth Amendment, which uses the same standards applicable to Eighth Amendment claims (ECF No. 37 at 3-4). The County is the only named defendant. Conklin correctly recognizes that a municipal entity may not be sued for the actions of its employees under respondeat superior, but can be sued when the policy or custom of the municipality itself was the driving force behind the violation (ECF No. 37 at 4). See Hightower v. City of Phila., No. 24-1116, 2024 WL 5453086, at *2 (3d Cir. Mar. 7, 2025) (citing Monell v. Dep't of Soc. Servs., 436 U.S. 658, 691 (1978)) (plaintiff “must show that the city's choices were the ‘moving force’ behind the constitutional

violation.”). Conklin argues that the County had an existing practice of “intentionally neglecting the medical and safety needs of the Plaintiff.” SAC ¶ 7.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Santiago v. Warminster Township
629 F.3d 121 (Third Circuit, 2010)
Burtch v. Milberg Factors, Inc.
662 F.3d 212 (Third Circuit, 2011)
Fowler v. UPMC SHADYSIDE
578 F.3d 203 (Third Circuit, 2009)
Univac Dental Co. v. Dentsply International, Inc.
702 F. Supp. 2d 465 (M.D. Pennsylvania, 2010)
John Doe v. University of the Sciences
961 F.3d 203 (Third Circuit, 2020)

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CONKLIN v. ALLEGHENY COUNTY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/conklin-v-allegheny-county-pawd-2025.