CRAMMER v. ANIMAL RESCUE LEAGUE

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 26, 2025
Docket5:25-cv-00715
StatusUnknown

This text of CRAMMER v. ANIMAL RESCUE LEAGUE (CRAMMER v. ANIMAL RESCUE LEAGUE) 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
CRAMMER v. ANIMAL RESCUE LEAGUE, (E.D. Pa. 2025).

Opinion

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

GARY MICHAEL CRAMMER, : Plaintiff, : : v. : CIVIL ACTION NO. 25-CV-0715 : ANIMAL RESCUE LEAGUE, et al. : Defendants. :

MEMORANDUM HENRY, J. MARCH 26, 2025 Currently before the Court is a Complaint filed by Plaintiff Gary Michael Crammer against the Animal Rescue League (“ARL”), unidentified ARL employees, and Lillian Crammer pursuant to 42 U.S.C. § 1983. Crammer seeks to proceed in forma pauperis. For the following reasons, the Court will grant Crammer leave to proceed in forma pauperis and dismiss his Complaint. I. FACTUAL ALLEGATIONS1 Utilizing a form Complaint, Crammer alleges that his privacy rights pursuant to the Health Insurance Portability and Accountability Act (“HIPAA”) were violated when Defendant Lillian Crammer (“Lillian”) told ARL that Crammer was in a treatment facility. (Compl. at 4, 7.) Crammer also avers that Lillian, who has a “durable power of attorney,” did not respect his wishes when she surrendered his dog, Donald J. Trump, to the ARL. (Id.) Crammer further asserts that ARL used the information obtained from Lillian against him when it refused to return his dog. (Id. at 4.) Crammer also contends that ARL and its employees, knowing that he was a

1 The factual allegations are taken from the Complaint (ECF No. 2) and the handwritten pages attached thereto. The Court adopts the sequential pagination supplied by the CM/ECF docketing system. “disabled vet,” tried to “intimidate” him by unnecessarily demanding proof of ownership. (Id. at 9-10.) As a result of Defendants’ actions, he has experienced mental anguish and depression. (Id. at 5.) Crammer claims that his HIPAA rights have been violated and he has been discriminated against because he is a “disabled veteran.”2 (Id. at 3, 5.) He seeks the revocation

of Lillian’s power of attorney, the return of Donald J. Trump, and monetary damages. (Id. at 5.) II. STANDARD OF REVIEW The Court grants Crammer leave to proceed in forma pauperis because it appears that he does not have the ability to pre-pay the fees to commence this case. Accordingly, 28 U.S.C. § 1915(e)(2)(B)(ii) requires the Court to dismiss the Complaint if it fails to state a claim. Whether a complaint fails to state a claim under § 1915(e)(2)(B)(ii) is governed by the same standard applicable to motions to dismiss under Federal Rule of Civil Procedure 12(b)(6), see Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999), which requires the Court to determine whether the complaint contains “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations omitted). ‘“At this

early stage of the litigation,’ ‘[the Court will] accept the facts alleged in [the pro se] complaint as true,’ ‘draw[] all reasonable inferences in [the plaintiff’s] favor,’ and ‘ask only whether [that] complaint, liberally construed, . . . contains facts sufficient to state a plausible [] claim.’”

2 Nothing in the Complaint suggests any factual basis for class-based or disability discrimination. Moreover, a passing reference without factual support is not sufficient to bring claims before a court. Brown v. Pennsylvania, Wayne Cnty., No. 22-1506, 2023 WL 3376547, at *2 (3d Cir. May 11, 2023), cert. dismissed sub nom. Brown v. Pennsylvania, 144 S. Ct. 272 (2023), reconsideration denied, 144 S. Ct. 417 (2023); see also Campbell v. LVNV Finding, LLC and Resurgent Capital Servs., No. 21-5388, 2022 WL 6172286, at *7 (E.D. Pa. Oct. 7, 2022) (stating that a “‘passing reference’ to jurisprudential precepts without more does not bring that issue before the Court in that it provides no basis for a ruling one way or the other.”) (citing Laborers’ Int’l Union of N. Am., AFL-CIO v. Foster Wheeler Energy Corp., 26 F.3d 375, 398 (3d Cir. 1994)). Shorter v. United States, 12 F.4th 366, 374 (3d Cir. 2021) (quoting Perez v. Fenoglio, 792 F.3d 768, 774, 782 (7th Cir. 2015)), abrogation on other grounds recognized by Fisher v. Hollingsworth, 115 F.4th 197 (3d Cir. 2024). Conclusory allegations do not suffice. Iqbal, 556 U.S. at 678.

As Crammer is proceeding pro se, the Court construes his allegations liberally. Vogt v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021) (citing Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 244-45 (3d Cir. 2013)). The Court will “apply the relevant legal principle even when the complaint has failed to name it.” Id. However, “pro se litigants still must allege sufficient facts in their complaints to support a claim.” Id. (quoting Mala, 704 F. 3d at 245). An unrepresented litigant “cannot flout procedural rules — they must abide by the same rules that apply to all other litigants.” Id. III. DISCUSSION A. HIPAA Claims Crammer seeks to bring claims pursuant to HIPAA. However, that statute does not

provide for a federal private right of action. See Baum v. Keystone Mercy Health Plan, 826 F. Supp. 2d 718, 721 (E.D. Pa. 2011); Dodd v. Jones, 623 F.3d 563, 569 (8th Cir. 2010); Webb v. Smart Document Solutions, LLC, 499 F.3d 1078, 1082 (9th Cir. 2007); Acara v. Banks, 470 F.3d 569 (5th Cir. 2006); Altavilla v. Geisinger Wyoming Valley Med. Ctr., No. 17-1704, 2018 WL 1630961, at *2 (M.D. Pa. Mar. 12, 2018), report and recommendation adopted, 2018 WL 1629870 (M.D. Pa. Apr. 4, 2018) (‘“The ability to bring an enforcement action to remedy HIPAA violations, and ensure that a healthcare provider is HIPAA compliant, lies within the exclusive province of the Secretary of Health and Human Services, not the hands of private citizens.’” (quoting Polanco v. Omnicell, Inc., 988 F. Supp. 2d 451, 469 (D.N.J. 2013)); see also Cobb v. PrimeCare Med. Corp., No. 18-1516, 2020 WL 13729620, at *6 (M.D. Pa. Jan. 29, 2020) (citations omitted), report and recommendation adopted, 2020 WL 13730063 (Feb. 24, 2020) (stating that HIPAA “does not create a private right of action for alleged disclosures of confidential medical information. . . . Therefore, neither [HIPAA] nor 42 U.S.C. § 1983

supports an action based on HIPPA violations.”) (internal quotation omitted). Accordingly, all claims asserting violations of HIPAA will be dismissed. B. Constitutional Claims Crammer seeks damages for alleged violations of his civil rights. (Compl. at 5.) The vehicle by which federal constitutional claims may be brought in federal court is 42 U.S.C. § 1983.

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Ashcroft v. Iqbal
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Dodd v. Jones
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Kelley Mala v. Crown Bay Marina
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499 F.3d 1078 (Ninth Circuit, 2007)
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Chambers v. Doe
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Miguel Perez v. James Fenoglio
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CRAMMER v. ANIMAL RESCUE LEAGUE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crammer-v-animal-rescue-league-paed-2025.