Denzel Arthur v. Officer Robert Rawley; Thomas Williams v. Officer Robert Rawley

CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 29, 2026
Docket2:25-cv-06299
StatusUnknown

This text of Denzel Arthur v. Officer Robert Rawley; Thomas Williams v. Officer Robert Rawley (Denzel Arthur v. Officer Robert Rawley; Thomas Williams 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.

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Denzel Arthur v. Officer Robert Rawley; Thomas Williams v. Officer Robert Rawley, (E.D. Pa. 2026).

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 has tried, in a Second Amended Complaint, to assert claims against Officer Robert Rawley and Blittersdorf’s Towing for seizing his car after a traffic stop. However, his Second Amended Complaint has no factual detail, just conclusory assertions. That’s not enough to state a plausible claim, so I will dismiss his claims. And, because he’s already had multiple bites at the apple, I will dismiss his claims with prejudice. I. BACKGROUND Officer Rawley stopped Mr. Williams on October 1, 2025, in Avondale Borough, while he was lawfully operating his personal vehicle. Blittersdorf’s Towing then seized and towed his vehicle without a warrant or (according to him) probable cause. He had to pay towing and recovery fees to regain possession of his vehicle. Despite the payment, Blittersdorf’s Towing retained his license plates, which prevents him from lawfully operating his vehicle. Blittersdorf’s Towing was operating at the “direction of law enforcement.” (ECF No. 11 at § III.C.) Mr. Williams contends that he was subjected to an unlawful seizure in violation of the Fourth Amendment.

Mr. Williams filed this lawsuit and a motion to proceed on November 4, 2025. On November 25, 2025, I denied the application for lack of sufficient financial information. The Order also noted the numerous deficiencies in

Mr. Williams’s Complaint and granted him leave to cure those deficiencies. On December 2, 2025, Mr. Williams filed a second motion for leave to proceed . He also filed a motion for leave to file an amended complaint, to which he attached an Amended Complaint. I granted the motion for leave to file an amended complaint and

screened the Amended Complaint pursuant to 28 U.S.C. § 1915(e)(2)(B). Upon screening, I dismissed with prejudice Mr. Williams’s First Amendment claims and claims against the Pennsylvania State Police and Avondale Police Department. I dismissed any Fourteenth Amendment due process claim seeking the return of his

property without prejudice to Mr. Williams’s right to pursue the return of his property in state court if appropriate, and if he chose to do so. But I did not give Mr. Williams leave to amend those claims. I did give Mr. Williams leave to amend his Fourth Amendment

claims. I explained that if he filed a second amended complaint, he must support his claims with factual allegations and must describe how each defendant was personally involved in the alleged violation of his rights. He filed a Second Amended Complaint (“SAC”) on January 13, 2026. II. STANDARD OF REVIEW Because I have granted Mr. Williams leave to proceed , 28 U.S.C.

§ 1915(e)(2)(B)(ii) requires me to dismiss the SAC if it fails to state a claim. That inquiry applies the standard for a motion to 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. “Although the plausibility standard does not impose a probability requirement, it does require a pleading to show more than a sheer possibility that a defendant has acted unlawfully.” , 809 F.3d 780, 786 (3d Cir. 2016) (internal

quotation marks and citations omitted). “A complaint that pleads facts merely consistent with a defendant’s liability stops short of the line between possibility and plausibility of entitlement to relief.” (cleaned up). When a plaintiff is proceeding , I construe his

allegations liberally. , 8 F.4th 182, 185 (3d Cir. 2021). III. DISCUSSION Mr. Williams asserts constitutional claims pursuant to 42 U.S.C. § 1983, the vehicle by which a plaintiff can pursue such claims 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, he has not alleged a plausible basis for a claim.

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). 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, traffic stops may be initiated based on a reasonable suspicion that a traffic violation has occurred. , 897

F.3d 173, 178 (3d Cir. 2018) (citing , 572 U.S. 393 (2014)). Where police have witnessed a traffic violation, a traffic stop is a reasonable seizure under the Fourth Amendment. , 111 F.3d 10, 12 (3d Cir. 1997). An

officer’s subjective reason for making a traffic stop plays no role in the reasonable suspicion analysis. , 517 U.S. at 812-13 Mr. Williams has not alleged facts that allow me to infer that any Defendant acted improperly. Although Mr. Williams again does not describe the circumstances of the October 1 traffic stop in the SAC, a review of the publicly available Pennsylvania state court docketing system reveals that Officer Rawley charged Mr. Williams was with seven

traffic on October 1, 2025.1 These violations remain pending. Notably, Pennsylvania law provides that when a law enforcement officer verifies that a person is operating a motor vehicle that does not have a valid registration or its registration has been suspended, “the

law enforcement officer shall immobilize the motor vehicle or combination or, in the interest of public safety, direct that the vehicle be towed and stored by the appropriate towing and storage agent ....” 75 Pa. Cons. Stat. Ann. § 6309.2(a)(2). Thus, if Officer Rawley had reason to believe that Mr. Williams was operating a vehicle with an invalid and/or

expired registration, it Officer Rawley could order the the car towed pursuant to Pennsylvania law. No. 22-4012, 2023 WL 144432, at *5 n.11 (E.D. Pa. Jan. 10, 2023).

1 , MJ-15304-TR-0004744-2025 (Chester) (speed violation in school zone, 75 Pa. Cons. Stat.

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