Fedder v. Snyder County (State of Pennsylvania)

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 18, 2022
Docket4:21-cv-01677
StatusUnknown

This text of Fedder v. Snyder County (State of Pennsylvania) (Fedder v. Snyder County (State of 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
Fedder v. Snyder County (State of Pennsylvania), (M.D. Pa. 2022).

Opinion

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

CHRISTOPHER FEDDER, : Civil No. 4:21-CV-1677 : Plaintiff, : : v. : : SNYDER COUNTY, : (Magistrate Judge Carlson) : Defendant. :

MEMORANDUM OPINION

I. Factual Background This is a pro se lawsuit brought by Christopher Fedder against Snyder County, Pennsylvania for alleged civil rights violations under 42 U.S.C. § 1983. Mr. Fedder’s current federal civil complaint appears to stem from his 2015 state court convictions for driving under the influence of alcohol and related traffic offenses. Commonwealth v. Fedder, CP-55-CR-0000285-2014. (Doc. 14-4). Fairly construed, Fedder’s federal civil complaint alleges that state officials engaged in a malicious prosecution of Fedder in 2015 based upon perjured testimony. However, it is noteworthy that Fedder has not succeeded in vacating or otherwise setting aside this state court conviction. Thus, Fedder remains convicted of these state criminal offenses. We further note that this federal lawsuit is not Fedder’s first foray in court as part of an effort to sue those who successfully prosecuted him in 2015. Quite the contrary, Fedder previously filed a state court lawsuit which made virtually identical allegations of malicious prosecution by state officials. Fedder v. Snyder County, CV-343-2016 (Ct. Cmmn Pleas, Snyder

County). That prior civil lawsuit was dismissed by the state court on September 29, 2021. (Doc. 14-5). It is against the backdrop of this prior criminal conviction in state court, a

conviction which remains unchallenged, and an unsuccessful prior civil lawsuit in state court which asserted legal claims identical to those advanced here, that Fedder now come to federal court seeking to repeat and reprise his malicious prosecution claims. (Doc. 1). The defendant has moved to dismiss Fedder’s pro se complaint,

arguing that it is untimely, fails to state a claim of agency liability, and is barred by both Fedder’s prior criminal conviction and by the dismissal of his prior state civil lawsuit. (Doc. 14). This motion is fully briefed by the parties, (Docs. 15, 19, and 20),

and is, therefore, ripe for resolution. For the reasons set forth below, the motion to dismiss will be granted. II. Discussion A. Motion to Dismiss – Standard of Review

A motion to dismiss tests the legal sufficiency of a complaint. It is proper for the court to dismiss a complaint in accordance with Rule 12(b)(6) of the Federal Rules of Civil Procedure only if the complaint fails to state a claim upon which relief

can be granted. Fed. R. Civ. P. 12(b)(6). With respect to this benchmark standard for the legal sufficiency of a complaint, the United States Court of Appeals for the Third Circuit has aptly noted the evolving standards governing pleading practice in federal

court, stating that: Standards of pleading have been in the forefront of jurisprudence in recent years. Beginning with the Supreme Court’s opinion in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), continuing with our opinion in Phillips [v. County of Allegheny, 515 F.3d 224, 230 (3d Cir. 2008)], and culminating recently with the Supreme Court’s decision in Ashcroft v. Iqbal, BU.S.B, 129 S. Ct. 1937 (2009), pleading standards have seemingly shifted from simple notice pleading to a more heightened form of pleading, requiring a plaintiff to plead more than the possibility of relief to survive a motion to dismiss.

Fowler v. UPMC Shadyside, 578 F.3d 203, 209-10 (3d Cir. 2009). In considering whether a complaint fails to state a claim upon which relief may be granted, the court must accept as true all allegations in the complaint and all reasonable inferences that can be drawn therefrom are to be construed in the light most favorable to the plaintiff. Jordan v. Fox, Rothschild, O’Brien & Frankel, Inc., 20 F.3d 1250, 1261 (3d Cir. 1994). However, a court “need not credit a complaint’s bald assertions or legal conclusions when deciding a motion to dismiss.” Morse v. Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997). Additionally, a court need not “assume that a . . . plaintiff can prove facts that the . . . plaintiff has not alleged.” Associated Gen. Contractors of Cal. v. California State Council of Carpenters, 459 U.S. 519, 526 (1983). As the Supreme Court held in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), in order to state a valid cause of action, a plaintiff must provide some factual grounds for relief which “requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of

actions will not do.” Id., at 555. “Factual allegations must be enough to raise a right to relief above the speculative level.” Id. In keeping with the principles of Twombly, the Supreme Court has

underscored that a trial court must assess whether a complaint states facts upon which relief can be granted when ruling on a motion to dismiss. In Ashcroft v. Iqbal, 556 U.S. 662 (2009), the Supreme Court held that, when considering a motion to dismiss, a court should “begin by identifying pleadings that, because they are no

more than conclusions, are not entitled to the assumption of truth.” Id., at 679. According to the Supreme Court, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id., at 678. Rather,

in conducting a review of the adequacy of a complaint, the Supreme Court has advised trial courts that they must: [B]egin by identifying pleadings that because they are no more than conclusions are not entitled to the assumption of truth. While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations. When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.

Id., at 679.

Thus, following Twombly and Iqbal, a well-pleaded complaint must contain more than mere legal labels and conclusions; it must recite factual allegations sufficient to raise the plaintiff’s claimed right to relief beyond the level of mere speculation. As the United States Court of Appeals for the Third Circuit has stated:

[A]fter Iqbal, when presented with a motion to dismiss for failure to state a claim, district courts should conduct a two-part analysis. First, the factual and legal elements of a claim should be separated. The District Court must accept all of the complaint’s well-pleaded facts as true, but may disregard any legal conclusions. Second, a District Court must then determine whether the facts alleged in the complaint are sufficient to show that the plaintiff has a “plausible claim for relief.” In other words, a complaint must do more than allege the plaintiff’s entitlement to relief. A complaint has to “show” such an entitlement with its facts.

Fowler, 578 F.3d at 210-11.

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

Related

Rooker v. Fidelity Trust Co.
263 U.S. 413 (Supreme Court, 1924)
Carey v. Piphus
435 U.S. 247 (Supreme Court, 1978)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
Memphis Community School District v. Stachura
477 U.S. 299 (Supreme Court, 1986)
Collins v. City of Harker Heights
503 U.S. 115 (Supreme Court, 1992)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Exxon Mobil Corp. v. Saudi Basic Industries Corp.
544 U.S. 280 (Supreme Court, 2005)
Lance v. Dennis
546 U.S. 459 (Supreme Court, 2006)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Santiago v. Warminster Township
629 F.3d 121 (Third Circuit, 2010)
Burtch v. Milberg Factors, Inc.
662 F.3d 212 (Third Circuit, 2011)
Robert Beck v. City of Pittsburgh
89 F.3d 966 (Third Circuit, 1996)
Morse v. Lower Merion School District
132 F.3d 902 (Third Circuit, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
Fedder v. Snyder County (State of Pennsylvania), Counsel Stack Legal Research, https://law.counselstack.com/opinion/fedder-v-snyder-county-state-of-pennsylvania-pamd-2022.