Ealy, Jr. v. County of Franklin

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 25, 2025
Docket3:25-cv-01235
StatusUnknown

This text of Ealy, Jr. v. County of Franklin (Ealy, Jr. v. County of Franklin) 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
Ealy, Jr. v. County of Franklin, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA VERNON L. EALY, JR., : No. 3:25-CV-1235 Plaintiff : } (Judge Munley) V. : FRANKLIN COUNTY, ef ai., : Defendants ;

MEMORANDUM Plaintiff Vernon L. Ealy, Jr., initiated the above-captioned pro se action under 42 U.S.C. § 1983, alleging multiple constitutional violations by Franklin County and Dauphin County officials. The court will dismiss Ealy’s complaint pursuant to 28 U.S.C. § 1915A(b)(1) for failure to state a claim upon which relief

may be granted but will provide leave to amend. I. BACKGROUND Ealy asserts that he was a pretrial detainee at all times referenced in his complaint. (Doc. 1 {] 3). He recounts that in 2019 and 2020, while detained at Franklin County Jail (FCJ), he made waves with the administration by advocatinc for better food at the prison, eventually gaining outside media attention. (ld. □□□ 18-22). Ealy additionally alleges that he filed multiple grievances and civil rights

1 Section 1983 creates a private cause of action to redress constitutional wrongs committed b state officials. The statute is not a source of substantive rights; it serves as a mechanism fe vindicating rights otherwise protected by federal law. See Gonzaga Univ. v. Doe, 536 U.S. 27° 284-85 (2002).

lawsuits concerning “inmates|’] rights” during this time. (Id. {] 19). He asserts that, after a coordinated food strike and the subsequent media scrutiny, he successfully negotiated with FCJ officials to obtain better meals for the inmates. (Id. J] 22-23). According to Ealy, on the eve of being transferred to another facility, he was granted bail in his pending criminal case. (Id. {] 23). Ealy returned to FCJ as a pretrial detainee on July 10, 2023. (Id. 25). The next day, he was transported to Dauphin County Prison (DCP)—60 miles away—by unknown “John Doe” FCJ transportation officials. (Id. ]27). After questioning both FCJ and DCP officials, Ealy was eventually informed that he

was transferred to DCP on a “Warden to Warden agreement.” (Id. YJ 26, 29). Ealy asserts that he endured unconstitutional conditions of confinement during his five-month detention at DCP. He alleges that there was extreme heat and no ventilation, bug and rodent infestations, malfunctioning toilets in the cells that would fill with feces and urine from adjoining cells, frequent lockdowns, and overcrowding. (Id. {J 30). Ealy next asserts several additional undeveloped claims. He first alleges that he is a Muslim and that he was denied his “religious freedoms” at DCP because he missed religious services and there was no “Taleem’” or “Jumah’” called during his DCP detention. (ld. 9] 31-32). He further claims that he was denied access to the courts because he signed up for law library but, due to the

long waiting list, never received law library access during his five months at DCP (Id. {| 34-35). Finally, he claims that numerous Defendants conspired to retaliate against him, including various prosecutors at the Franklin County Distric Attorney’s Office. (Id. Jf] 43, 56-58). Ealy sues thirteen defendants: Franklin County District Attorney Brink, Franklin County Assistant District Attorney Faust, FCJ Warden Schell, FCJ Deputy Warden Weller, FCJ Deputy Warden Franzoni, FCJ Deputy Warden scott, FCJ Major Morrow, FCJ Captain Arter, FCJ “Director of Treatment’ Sterner, two “John Doe” officers at FCJ, DCP Warden Briggs, and DCP Deputy Warden Pierre.” (Id. ff] 4-16). He seeks retroactive declaratory relief that his rights were violated, various forms of prospective injunctive relief, nominal damages, compensatory damages, and punitive damages. (ld. at pp. 10-11). ll. STANDARD OF REVIEW Courts are statutorily obligated to review, “as soon as practicable,” unrepresented prisoner complaints targeting governmental entities, officers, or employees. See 28 U.S.C. § 1915A(a). One basis for dismissal at the screening stage is if the complaint “fails to state a claim upon which relief may be granted[.]” Id. § 1915A(b)(1). This language closely tracks Federal Rule of Civil

2 Ealy also lists “Franklin County” as a defendant in his caption, but he does not identify the county as a defendant in the body of his complaint, nor does he proffer any cognizable Sectior 1983 allegations against the county.

Procedure 12(b)(6). Accordingly, courts apply the same standard to screening a

pro se prisoner complaint for sufficiency under Section 1915A(b)(1) as they utilize when resolving a motion to dismiss under Rule 12(b){6). See Grayson v. Mayview State Hosp., 293 F.3d 103, 109-10 &n.11 (3d Cir. 2002); O'Brien v. U.S. Fed. Gov't, 763 F. App’x 157, 159 & n.5 (3d Cir. 2019) (per curiam) (nonprecedential); cf. Allah v. Seiverling, 229 F.3d 220, 223 (3d Cir. 2000). In deciding a Rule 12(b){6) motion to dismiss, courts should not inquire “whether a plaintiff will ultimately prevail but whether the claimant is entitled to offer evidence to support the claims.” Scheuer v. Rhodes, 416 U.S. 232, 236 (1974); see Nami v. Fauver, 82 F.3d 63, 66 (3d Cir. 1996). The court must accept as true the factual allegations in the complaint and draw all reasonable inferences from them in the light most favorable to the plaintiff. See Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). In addition to the facts alleged on the face of the complaint, the court may also consider “exhibits attached to the complaint, matters of public record, as well as undisputedly authentic documents” attached to a defendant's motion to dismiss if the plaintiff's claims are based upon these documents. Mayer v. Belichick, 605 F.3d 223, 230 (3d Cir. 2010) (citing Pension Benefit Guar. Corp. v. White Consol. Indus., 998 F.2d 1192, 1196 (3d Cir. 1993)).

When the sufficiency of a complaint is challenged, the court must conduct <

three-step inquiry. See Connelly v. Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal citations and quotation marks omitted) (footnote omitted). At

step one, the court must “tak[e] note of the elements [the] plaintiff must plead to

state a claim.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 675 (2009) (alterations in original)). Second, the court should distinguish well-pleaded factual allegations—which must be taken as true—from mere legal conclusions, which “are not entitled to the assumption of truth” and may be disregarded. Id. (quoting Iqbal, 556 U.S. at 679). Finally, the court must review the presumed- truthful allegations “and then determine whether they plausibly give rise to an

entitlement to relief.” Id. (quoting Iqbal, 556 U.S. at 679). Deciding plausibility is

a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Iqbal, 556 U.S. at 681. Because Ealy proceeds pro se, his pleadings are to be liberally construed

and his complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers[.]’ Erickson v. Pardus, 551

U.S. 89, 94 (2007) (citations omitted). This is particularly true when the pro se

litigant, like Ealy, is incarcerated. See Dooley v. Wetzel, 957 F.3d 366, 374 (3d Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Wisconsin v. Yoder
406 U.S. 205 (Supreme Court, 1972)
Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Pembaur v. City of Cincinnati
475 U.S. 469 (Supreme Court, 1986)
Turner v. Safley
482 U.S. 78 (Supreme Court, 1987)
O'Lone v. Estate of Shabazz
482 U.S. 342 (Supreme Court, 1987)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Lewis v. Casey
518 U.S. 343 (Supreme Court, 1996)
Christopher v. Harbury
536 U.S. 403 (Supreme Court, 2002)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mayer v. Belichick
605 F.3d 223 (Third Circuit, 2010)
Newman v. Beard
617 F.3d 775 (Third Circuit, 2010)
Centifanti v. Nix
865 F.2d 1422 (Third Circuit, 1989)
Colburn v. Upper Darby Township
946 F.2d 1017 (Third Circuit, 1991)
Nami v. Fauver
82 F.3d 63 (Third Circuit, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
Ealy, Jr. v. County of Franklin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ealy-jr-v-county-of-franklin-pamd-2025.