Denzel Arthur v. Officer Robert Rawley

CourtDistrict Court, E.D. Pennsylvania
DecidedDecember 12, 2025
Docket2:25-cv-06299
StatusUnknown

This text of Denzel Arthur v. Officer Robert Rawley (Denzel Arthur v. Officer Robert Rawley) 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
Denzel Arthur v. Officer Robert Rawley, (E.D. Pa. 2025).

Opinion

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

DENZEL ARTHUR : THOMAS WILLIAMS, : Plaintiff, : : v. : Case No. 2:25-cv-06299-JDW : OFFICER ROBERT RAWLEY, , : Defendants. :

MEMORANDUM

Denzel Arthur Thomas Williams asserts claims for violations of his Constitutional rights based on the seizure of his car after a traffic stop. I will grant Mr. Williams leave to file an amended complaint (which he could have done as of right anyway) and grant him leave to proceed . I will dismiss his Amended Complaint but give him leave to file a second amended complaint to re-plead some of the claims he asserts. Other claims, I will dismiss without a chance to amend because there is no way that Mr. Williams could amend those claims to make them plausible. I. FACTUAL ALLEGATIONS On October 1, 2025, Officer Robert Rawley and the Avondale Police Department seized Mr. Williams’s vehicle without a warrant or probable cause. His five-year-old child was present during the seizure. Blittersdorf’s Towing & Recovery retained the vehicle and his property and refused to return it despite repeated requests. The Pennsylvania State Police did not intervene or provide proper oversight. After Mr. Williams paid the towing and recovery fees to retrieve his vehicle, his Defendants retained his license plates, which prevents him from using the vehicle.

Mr. Williams contends that he was subjected to an unlawful seizure in violation of the Fourth Amendment, retaliation and intimidation in violation of the First Amendment,1 and due process violations under the Fourteenth Amendment for the deprivation of his

property. He claims to have suffered a loss of property, as well as emotional distress and endangerment to his child.2 II. STANDARD OF REVIEW A plaintiff seeking leave to proceed must establish that she is

unable to pay for the costs of her suit. , 886 F.2d 598, 601 (3d Cir. 1989). Where, as here, a court grants a plaintiff leave to proceed , it must determine whether the complaint states a claim on which relief may be granted. 28 U.S.C. § 1915(e)(2)(B)(ii). That inquiry applies the standard for a motion to

1 Mr. Williams presents no factual allegations in support of his assertion that his First Amendment rights were violated. Passing references to legal provisions are insufficient to bring a plausible claim before the Court. , 62 F.4th 755, 763 (3d Cir. 2023) (“A passing reference to an issue will not suffice to bring that issue before this court.” (cleaned up) (quoting , 26 F.3d 375, 398 (3d Cir. 1994))). Accordingly, any claim based on a violation of the First Amendment will be dismissed.

2 Mr. Williams makes clear in the Amended Complaint that he does not seek to bring claims on behalf of his minor child and includes facts regarding his child to show the context and severity of the incident. ( ECF No. 7-1 at 2.) dismiss under Fed. R. Civ. P. 12(b)(6). Pursuant to that standard, I must determine whether the Complaint contains “sufficient factual matter, accepted as true, to state a claim to

relief that is plausible on its face.” , 556 U.S. 662, 678 (2009) (quotations omitted). That means I must accept the factual allegations in the Complaint as true, draw inferences in favor of the plaintiff, and determine whether there is a plausible claim.

, 12 F.4th 366, 374 (3d Cir. 2021). Conclusory allegations do not suffice. , 556 U.S. at 678. When a plaintiff is proceeding ,, I construe her allegations liberally. , 8 F.4th 182, 185 (3d Cir. 2021). III. DISCUSSION

A. Mr. Williams has completed the required forms and attests under penalty of perjury that he lacks the income or assets to pay the required filing fees. I will therefore grant him leave to proceed .

B. Plausibility Of Claims Mr. Williams asserts constitutional claims pursuant to § 1983, the vehicle by which such claims may be brought against state actors in federal court. “To state a claim under

§ 1983, a plaintiff must allege the violation of a right secured by the Constitution and laws of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.” , 487 U.S. 42, 48 (1988). Even liberally construing Mr. Williams’s allegations as this Court must, he has not alleged a plausible basis for a claim against any of the named Defendants.

1. Claims against government entities Mr. Williams’s claims against various government entities fail for several reasons. , the Eleventh Amendment bars his claims against the Pennsylvania State Police

because the State Police is an agency of the State. , 574 F. Supp. 3d 272, 284 (E.D. Pa. 2021). Also, a State (including its agencies) is not a “person” under Section 1983. , Mr. Williams’s claims against the City of Avondale fail because he has not

alleged any facts to establish the City’s liability. A municipality is not vicariously liable under § 1983 for the actions of its employees. , 563 U.S. 51, 60 (2011). Rather, to plead a § 1983 claim against a municipality such as Avondale, a plaintiff must allege that the municipality or contractor’s policy or custom caused the violation of

his constitutional rights. , 436 U.S. 658, 694 (1978). “To satisfy the pleading standard, [the plaintiff] must ... specify what exactly that custom or policy was.” , 564 F.3d 636, 658 (3d Cir. 2009) (citation omitted). Mr. Williams has not

falls short of that standard. He just claims in a conclusory fashion that Avondale is liable under for policies, customs, or practices leading to the violation of his rights. That’s not enough. If he asserts a claim against Avondale in an amended pleading, he must be more specific about what the custom or policy was and how it led to his injury. , Mr. Williams’s claims against the Avondale Police Department fail because a police department is not a separate entity subject to suit.

, 834 F. Supp. 873, 878-79 (W.D. Pa. 1993). Thus, while a municipality may be liable under § 1983, a police department, as a mere sub-unit of the municipality, may not. .

2. Fourth Amendment The Fourth Amendment guarantees “[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.” U.S. Const. amend. IV. “Generally, for a seizure to be reasonable under the Fourth Amendment,

it must be effectuated with a warrant based on probable cause.” , 672 F.3d 232, 237 (3d Cir. 2012) (quote omitted). It is well-settled that the temporary detention of an individual during a traffic stop is a “seizure” of “persons” under the Fourth Amendment. , 517 U.S. 806, 809-10 (1996). However, police may

initiate traffic stops based on a reasonable suspicion that a traffic violation has occurred. , 897 F.3d 173, 178 (3d Cir. 2018).

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