Elizabeth A. Hibble, Personally, on behalf of CRH, a minor, and as the Administratrix of the Estate of Michael W. Brook, and Elijah L. Rothell v. City of Harrisburg, Pennsylvania

CourtDistrict Court, M.D. Pennsylvania
DecidedJune 29, 2026
Docket1:25-cv-00636
StatusUnknown

This text of Elizabeth A. Hibble, Personally, on behalf of CRH, a minor, and as the Administratrix of the Estate of Michael W. Brook, and Elijah L. Rothell v. City of Harrisburg, Pennsylvania (Elizabeth A. Hibble, Personally, on behalf of CRH, a minor, and as the Administratrix of the Estate of Michael W. Brook, and Elijah L. Rothell v. City of Harrisburg, Pennsylvania) 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
Elizabeth A. Hibble, Personally, on behalf of CRH, a minor, and as the Administratrix of the Estate of Michael W. Brook, and Elijah L. Rothell v. City of Harrisburg, Pennsylvania, (M.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA ELIZABETH A. HIBBLE, Personally, : Civil No. 1:25-CV-00636 on behalf of CRH, a minor, and as the : Administratrix of the Estate of Michael : W. Brook, and : ELIJAH L. ROTHELL, : : Plaintiffs, : : v. : : CITY OF HARRISBURG, : PENNSYLVANIA, : : Defendant. : Judge Jennifer P. Wilson MEMORANDUM The court dismissed Plaintiffs’ state-created danger claim with prejudice. Plaintiffs now claim this was clear error. They filed a post-judgment motion asking the court either to reconsider its ruling or to alter judgment so they can file a second amended complaint. For the reasons that follow, the court will deny Plaintiffs’ motion. BACKGROUND1 Michael Brook (“Brook”) and Elijah Rothell (“Rothell”) were boating on the Susquehanna River when a mechanical failure caused their boat to drift over the Dock Street Dam (“Dam”). The accident tragically killed Brook and injured

1 The court assumes familiarity with its previous memorandum opinion in this matter. Hibble v. City of Harrisburg, No. 25-cv-00636, 2026 WL 312706 (M.D. Pa. Feb. 5, 2026). Rothell. The administratrix of Brook’s estate and Rothell (“Plaintiffs”) sued the Dam’s owner, the City of Harrisburg (“Harrisburg”). Plaintiffs asserted in their

first amended complaint, inter alia, a § 1983 state-created danger claim.2 (Doc. 19, ¶¶ 135–60.) Harrisburg successfully moved to dismiss that claim. The primary issue

litigated was whether Plaintiffs adequately pleaded that they were “member[s] of a discrete class of persons subjected to the potential harm brought about by the state's actions, as opposed to a member of the public in general.” Hibble, 2026 WL 312706, at *3, 5–6. Plaintiffs claimed that the discrete class of which they were

members was “boaters in the exclusion zone,” Doc. 19, ¶ 137, which included the areas directly upstream and downstream of the Dam that were not open to the public, id. ¶ 117.

The court identified two problems with Plaintiffs’ discrete-class theory. First, the class was artificially underinclusive of those who actually faced the alleged state-created danger, i.e., the Dam itself. Hibble, 2026 WL 312706, at *5. As the court explained:

Plaintiffs' proposed class is underinclusive with respect to both persons subject to the risk of harm and the geographic scope of where that risk exists. The Dam creates a risk for many more people than just boaters in the exclusion zone. Anyone on or in the Susquehanna River near the

2 Plaintiffs also asserted state-law claims. (Doc. 19, ¶¶ 168–86.) The court declined to exercise supplemental jurisdiction over these claims once it dismissed the § 1983 claim. Hibble, 2026 WL 312706, at *6–7. Dam would face the same risk, whether they are boaters or a person who by happenstance finds themselves in the river near the Dam. Moreover, the tragic facts of this case illustrate that the risk of harm is present far beyond the exclusion zone. Plaintiffs never intended to enter the exclusion zone; they drifted three miles from the recreational lake into it due to the malfunction of Brook's boat. (See Doc. 19, ¶¶ 24, 67, 71, 76.) Hibble, 2026 WL 312706, at *5. Second, the class of persons who actually faced the alleged danger posed by the Dam—anyone in the Susquehanna River within a reasonable distance of the Dam—was limited neither in time nor scope. Id. at *5– 6. The court concluded that such a “class contains an indeterminate number of potential plaintiffs,” has existed since the Dam was built in 1913, and will continue to exist for as long as the Dam remains in its current state. Id. Given this, the court ruled that Plaintiffs’ class was not discrete enough to support a state-created danger claim. Id. at *6. STANDARD OF REVIEW

Plaintiffs’ requests to alter judgment and to file a second amended complaint are governed by Federal Rules of Civil Procedure 59(e) and 15(a), respectively. A Rule 59(e) motion typically requires the court to consider whether the movant has

shown: “(1) an intervening change in controlling law; (2) the availability of new evidence; or (3) the need to correct clear error of law or prevent manifest injustice.”3 Burtch v. Milberg Factors, Inc., 662 F.3d 212, 230 (3d Cir. 2011) (quoting Lazaridis v. Wehmer, 591 F.3d 666, 669 (3d Cir. 2010)). The analysis is

different, however, when the Rule 59(e) motion seeks post-judgment leave to amend the complaint. In those circumstances, “the Rule 15 and 59 inquiries turn on the same factors.” Id. (quoting In re Adams Golf, Inc. Sec. Litig., 381 F.3d 267,

280 (3d Cir. 2004)); Cureton v. NCAA, 252 F.3d 267, 272 (3d Cir. 2001); Adams v. Gould Inc., 739 F.2d 858, 864 (3d Cir. 1984). Those factors include, but are not limited to, “undue delay, bad faith or dilatory motive on the part of the movant; repeated failure to cure deficiencies by amendments previously allowed; prejudice

to the opposing party; and futility.” Mullin v. Balicki, 875 F.3d 140, 149 (3d Cir. 2017); accord Foman v. Davis, 371 U.S. 178, 182 (1962). While Rule 15 calls for leave to be “freely give[n],” Fed. R. Civ. P. 15(a)(2), “the liberality of the rule is

no longer applicable once judgment has been entered.” Ahmed v. Dragovich, 297 F.3d 201, 207–08 (3d Cir. 2002); accord S. Jersey Gas Co. v. Mueller Co., Ltd., 429 F. App’x 128, 130 (3d Cir. 2011). DISCUSSION

Plaintiffs argue that the court misunderstood their allegations and conceptualized the class of persons subject to the state-created danger at too high a

3 These are the same factors that guide courts deciding whether to grant a motion for reconsideration. Max’s Seafood Cafe ex rel. Lou-Ann, Inc. v. Quinteros, 176 F.3d 669, 677 (3d Cir. 1999) (citing N. River Ins. Co. v. CIGNA Reinsurance Co., 52 F.3d 1194, 1218 (3d Cir. 1995)). level of generality. (Doc. 36, pp. 4–8.)4 They contend that the alleged state- created danger was not the Dam itself but, rather, Harrisburg’s commitment to

place warning markers upstream from the Dam and its subsequent decision to remove them. (Id. at 5.) On this theory, Plaintiffs insist that their class is limited to anyone who entered a specific geographic area—the Susquehanna River

upstream from the Dam but downstream from where the warning markers would have and/or should have been—during a specific time—when the warning markers were not deployed after Harrisburg committed to deploying them. (Id. at 6–7.) Plaintiffs claim the court committed clear error by not considering the viability of

this class. (Id. at 4–8.) As relief, Plaintiffs seek either reconsideration of the court’s order dismissing the first amended complaint or leave to file a second amended complaint that clarifies this theory.

The court need not get hung up on Plaintiffs’ reconsideration request. Even assuming, without deciding, that Plaintiffs actually pleaded their rearticulated discrete-class theory in the first amended complaint, the time and scope defects the court previously identified still apply.5

4 For ease of reference, the court uses the page numbers from the CM/ECF header.

5 This is not to mention other problems.

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
South Jersey Gas Co. v. Mueller Co.
429 F. App'x 128 (Third Circuit, 2011)
Adams v. Gould Inc.
739 F.2d 858 (First Circuit, 1984)
Burtch v. Milberg Factors, Inc.
662 F.3d 212 (Third Circuit, 2011)
Walter v. Pike County, Pa.
544 F.3d 182 (Third Circuit, 2008)
Lazaridis v. Wehmer
591 F.3d 666 (Third Circuit, 2010)
Mark v. Borough of Hatboro
51 F.3d 1137 (Third Circuit, 1995)
Ahmed v. Dragovich
297 F.3d 201 (Third Circuit, 2002)
Joan Mullin v. Karen Balicki
875 F.3d 140 (Third Circuit, 2017)
June-Lori Mears v. Elizabeth Connolly
24 F.4th 880 (Third Circuit, 2022)

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Bluebook (online)
Elizabeth A. Hibble, Personally, on behalf of CRH, a minor, and as the Administratrix of the Estate of Michael W. Brook, and Elijah L. Rothell v. City of Harrisburg, Pennsylvania, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elizabeth-a-hibble-personally-on-behalf-of-crh-a-minor-and-as-the-pamd-2026.