DORSEY v. PENNSBURY SCHOOL DISTRICT

CourtDistrict Court, E.D. Pennsylvania
DecidedSeptember 28, 2021
Docket2:20-cv-00863
StatusUnknown

This text of DORSEY v. PENNSBURY SCHOOL DISTRICT (DORSEY v. PENNSBURY SCHOOL DISTRICT) 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
DORSEY v. PENNSBURY SCHOOL DISTRICT, (E.D. Pa. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA KEVIN DORSEY, : CIVIL ACTION Plaintiff : v. : PENNSBURY SCHOOL □ DISTRICT et al., : No. 20-863 Defendant : MEMORANDUM Af PRATTER, J. SEPTEMBER , 202] Civil-rights plaintiffs need only make out a short and plain statement of their claims. But that statement must still be thorough enough to tie each defendant to the alleged violation. Kevin Dorsey sued his former employer, the Pennsbury School District, its superintendent, and four board members for gender discrimination. But he has not said how the board members violated his rights, nor how they conspired with the superintendent to do so. The Court thus dismisses his § 1983 claims against the board members in their individual capacities and his § 1985 claim against all defendants without prejudice. BACKGROUND Kevin Dorsey worked as the Director of Information Technology for Pennsbury School District until, he alleges, he was pushed out due to gender discrimination. Am. Compl. € 8. Mr. Dorsey is in a same-sex marriage. /d. J 1. Because he did not “conform to traditionally held gender stereotypes,” he says, the district and its employees discriminated against him. Jd € 15. Specifically, they called him a “fag—t,” paid him less than his peers, and left him out of meetings. Id. 4 15. When Mr. Dorsey reported this, the district punished him. /d. He was also falsely accused of misconduct around the office. /d. In one incident, the district accused him “of listening to other people’s voice mails.” fd, Pending an investigation, the district placed Mr. Dorsey on administrative leave, prompting him to resign. fd. J 17, 20.

Mr. Dorsey sued the district, its superintendent, and four members of the schoo] board, He claims that they violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000(¢) ef seg. and the Pennsylvania Human Relations Act, 43 Pa. Stat. §§ 951 ef seg., because they discriminated against him based on his gender and sexual orientation. He likewise seeks monetary damages under 42 U.S.C. § 1983, asserting that the district and its officials denied his right to equal protection under the Fourteenth Amendment and infringed on his First Amendment rights by retaliating against him when he complained about their actions. He also accuses the officials of conspiring to infringe his constitutional and statutory rights, in violation of 42 U.S.C. § 1985. The district and its officials now move to dismiss his § 1983 and § 1985 claims for failure to state a claim. Fed. R. Civ. P. 12(b}(6). LEGAL STANDARDS In his complaint, a plaintiff must set out “a short and plain statement of the claim showing that [he] is entitled to relief.” Fed, R. Civ. P. 8(a)(2). That statement cannot just be “a formulaic recitation of the elements of” the law. Bell Ad. Corp. v. Twombly, $50 U.S. 544, 555 (2007). It must also include facts, and enough to push the claim from merely possible to “plausible.” Jd. at 555-56, In deciding a motion to dismiss for failure to state a claim, the Court strips away the bare legal conclusions and asks if, taking the well-pleaded facts as true, the plaintiff has made out a plausible claim against each defendant. Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). DISCUSSION L Mr. Dorsey has not stated plausible § 1983 claims against the officials For the § 1983 claims, the officials assert that they are not the correct defendants. Besides, the board members argue, Mr. Dorsey did not provide enough detail to tie them to the claimed discrimination. Because the board members are right on the second point, the Court dismisses the § 1983 claims against them without prejudice.

A. The individual-capacity claims are not duplicative Mr. Dorsey sues both the district and its officials. So, the officials contend, the claims against them are duplicative and should be dismissed. For actions taken under color of law, government officials can be sued in their official capacities, as government actors, or in their personal capacities, as individuals. Kentucky v. Graham, 473 U.S. 159, 165 (1985). Here, Mr. Dorsey appears to sue the district officials for damages in both their official and individual capacities. See Pl.’s Br, 3. His official-capacity claims are redundant. If a plaintiff sues a municipal official for damages in his official capacity, he seeks to recover from the municipal’s coffers. Graham, 473 U.S. at 166. In other words, the suit “is, in all respects other than name, ... a suit against” his employer. /d. Because “the real party in interest is the” employer, the official can and should be dismissed, so long as the employer “receives notice” of the claims “and an opportunity to respond.” Id., accord Baez v. Lancaster Cnty., 487 F. App’x 30, 32 (3d Cir. 2012); Stanek v. St. Charles Cmty, Unit Sch. Dist. No. 303, 783 F.3d 634, 644 (7th Cir. 2015); Ctr. for Bio-Ethical Reform, Inc. v. L.A. Cnty. Sheriff Dep't, 533 F.3d 780, 799 (9th Cir. 2008). Mr. Dorsey has brought the exact same § 1983 claim against the district as he did the officials. The Court thus dismisses his duplicative claims against them in their official capacities. But his claims against the officials in their personal capacities are mof redundant. If successful, his claims against the district will be paid out of its coffers, while his individual claims against the officials target their “personal assets.” Graham, 473 U.S. at 166. Further, the proof required for each is different. For his individual-capacity claims, Mr. Dorsey must “show that the official[s], acting under color of state law,” deprived him of his federal rights. Graham, 473 U.S. at 166. For his claim against the district, he must go a step further and show that the district’s

“policy or custom” caused the violation. □□ (quoting Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658, 694 (1978)). So his claims against the district and against the officials in their personal capacities can coexist. B. The individual-capacity claims are implausible Though his claims against the board members in their individual capacities are not redundant, they are too general. To state a claim against the individual officials, Mr. Dorsey must plausibly plead that each official had “personal invoivement in the alleged wrongdoing.” Evancho vy. Fisher, 423 F.3d 347, 353 Gd Cir. 2005). Mr. Dorsey articulates the discriminatory “conduct, time, [and] place.” Jd. And he points to five officials that he asserts discriminated against him: Superintendent William Gretzula and board members Christine Toy-Dragoni, Debra Wachspress, Joshua Waldorf, and T.R. Kannan. Yet he does not match the board members to any of the discriminatory conduct. For Superintendent William Gretzula, Mr. Dorsey has shown “personal involvement.” Evancho, 423 F.3d at 353. Dr. Gretzula called him a “destructive force” at a meeting and then threatened “reprisal” after Mr. Dorsey reported him. Am. Compl. § 15. Later, Mr. Gretzula “falsely accus[ed]” him of a crime in front of the school board. /d. In contrast, Mr.

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Baez Ex Rel. Estate of Villafane v. Lancaster County
487 F. App'x 30 (Third Circuit, 2012)
Farber v. City of Paterson
440 F.3d 131 (Third Circuit, 2006)

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Bluebook (online)
DORSEY v. PENNSBURY SCHOOL DISTRICT, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dorsey-v-pennsbury-school-district-paed-2021.