Cutler v. Bellefonte Area School District

97 F. Supp. 3d 586, 2015 U.S. Dist. LEXIS 31677, 2015 WL 1198330
CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 16, 2015
DocketNo. 4:14-CV-01758
StatusPublished
Cited by3 cases

This text of 97 F. Supp. 3d 586 (Cutler v. Bellefonte Area School District) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cutler v. Bellefonte Area School District, 97 F. Supp. 3d 586, 2015 U.S. Dist. LEXIS 31677, 2015 WL 1198330 (M.D. Pa. 2015).

Opinion

MEMORANDUM

MATTHEW W. BRANN, District Judge.

Before the Court for disposition is Defendant Jeffrey Steiner’s Motion to Dismiss Plaintiffs Complaint. (ECF No. 11). For the following reasons, Defendant’s Motion is granted and the defamation claim within Plaintiff Elaine Cutler’s Complaint is dismissed with prejudice.

[587]*587I. BACKGROUND

On September 9, 2014, Plaintiff Elaine Cutler filed a Complaint with this Court alleging unlawful discrimination against Bellefonte Area School District and defamation against individual defendant, Jeffrey Steiner. (ECF No. 1). Plaintiff specifically alleges that, by terminating her as principal of Bellefonte Elementary School, Defendant Bellefonte Area School District violated the Age Discrimination in Employment Act, Americans with Disabilities Act, and the Pennsylvania Human Relations Act. Against individual Defendant Jeffrey Steiner, Plaintiff alleges a state law claim of defamation. This claim of defamation arises from statements made by Defendant in his capacity as a school board member for the Bellefonte Area School District. Specifically, at a September 10, 2013 public hearing before the school board, Defendant Steiner stated that he needed to “quantify for people to understand” the decision to terminate Plaintiff. He then described the cause for termination of Plaintiff as including her perpetration of “three (3) Class A Felonies and misdemeanors.”

On November 12, 2014, Defendant Jeffrey Steiner filed a Motion to Dismiss and an accompanying Memorandum of Law arguing that he was entitled to absolute immunity as a “high public official” and that Plaintiffs complaint failed to state a claim upon which relief can be granted. (ECF No. 12). On November 26, 2014, Plaintiff filed a Brief in Opposition to Defendant’s Motion arguing that Defendant Steiner was ineligible for absolute immunity because his statements went beyond his official authority as a member of the Belle-fonte Area school board. (ECF No. 14). Defendant subsequently filed a Reply Brief on December 3, 2014, (ECF No. 15), bringing the case to its present posture.

II. DISCUSSION

A. MOTION TO DISMISS STANDARD

When considering a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a court must view all allegations stated in the complaint as true and construe all inferences in the light most favorable to plaintiff. Hishon v. King & Spalding, 467 U.S. 69, 73, 104 S.Ct. 2229, 81 L.Ed.2d 59 (1984); Kost v. Kozakiewicz, 1 F.3d 176, 183 (3d Cir.1993). However, “the tenet that a court must accept as true all of the [factual] allegations contained in the complaint is inapplicable to legal conclusions.” Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009) (internal citations omitted). In -ruling on such a motion, the court primarily considers the allegations of the pleading, but is not required to consider legal conclusions alleged in the complaint. Kost, 1 F.3d at 183. “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678, 129 S.Ct. 1937. At the motion to dismiss stage, the court considers whether plaintiff is entitled to offer evidence to support the allegations in the complaint. Maio v. Aetna, Inc., 221 F.3d 472, 482 (3d Cir.2000).

A complaint should only be dismissed if, accepting as true all of the allegations in the amended complaint, plaintiff has not pled enough facts to state a claim to relief that is plausible on its face. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 561, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007). “Determining whether a complaint states a plausible claim for relief will ... be a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 663-664, 129 S.Ct. 1937. “In .considering a Rule 12(b)(6) motion, we must be mindful that federal courts require notice pleading, as opposed to the heightened [588]*588standard of fact pleading.” Hellmann v. Kercher, No. 07-1373, 2008 WL 1969311 at *3 (W.D.Pa. May 5, 2008) (Lancaster, J.). Federal Rule of Civil Procedure 8 “requires only a ‘short and plain statement of the claim showing that the pleader is entitled to relief,’ in order to ‘give the defendant fair notice of what the ... claim is and the grounds on which it rests’.” Bell Atlantic Corp. v. Twombly, 550 U.S. at 554, 127 S.Ct. 1955 (quoting Conley v. Gibson, 355 U.S. 41, 47, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957)). However, even under this lower notice pleading standard, a plaintiff must do more than recite the elements of a cause of action, and then make a blanket assertion of an entitlement to relief. See Hellmann, 2008 WL 1969311 at *3. Instead, a plaintiff must make a factual showing of his entitlement to relief by alleging sufficient facts that, when taken as true, suggest the required elements of a particular legal theory. See Twombly, 550 U.S. at 561, 127 S.Ct. 1955. “[W]here the well-pleaded facts do not permit the court to infer more than the mere possibility of misconduct, the complaint has alleged— but it has not “shown” — “that the pleader is entitled to relief.” ” Iqbal, 556 U.S. at 679, 129 S.Ct. 1937 (quoting Fed.R.Civ.P. 8(a)).

The failure-to-state-a-claim standard of Rule 12(b)(6) “streamlines litigation by dispensing with needless discovery and fact-finding.” Neitzke v. Williams, 490 U.S. 319, 326-27, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989). A court may dismiss a claim under Rule 12(b)(6) where there is a “dis-positive issue of law.” Id. at 326, 109 S.Ct. 1827. If it is beyond a doubt that the non-moving party can prove no set of facts in support of its allegations, then a claim must be dismissed “without regard to whether it is based on an outlandish legal theory or on a close but ultimately unavailing one.” Id. at 327, 109 S.Ct. 1827.

B. ANALYSIS

Accepting as true all of the allegations contained in Plaintiffs Complaint, the Court nevertheless finds that Defendant Jeffrey Steiner is entitled to absolute immunity because of his status as a “high public official.” Because this immunity exempts him from liability for defamatory statements, this Court grants Defendant’s Motion to Dismiss Plaintiffs claim of defamation. Furthermore, because a finding of absolute immunity for Defendant is entirely dispositive as to Plaintiffs defamation claim, the Court’s analysis will be restricted to that discussion.

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97 F. Supp. 3d 586, 2015 U.S. Dist. LEXIS 31677, 2015 WL 1198330, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cutler-v-bellefonte-area-school-district-pamd-2015.