FRANTY v. FAYETTE COUNTY HOUSING AUTHORITY

CourtDistrict Court, W.D. Pennsylvania
DecidedMarch 28, 2025
Docket2:22-cv-01096
StatusUnknown

This text of FRANTY v. FAYETTE COUNTY HOUSING AUTHORITY (FRANTY v. FAYETTE COUNTY HOUSING AUTHORITY) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
FRANTY v. FAYETTE COUNTY HOUSING AUTHORITY, (W.D. Pa. 2025).

Opinion

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

JARROD FRANTY ) ) Plaintiff, ) ) v. ) Civil Action No. 22-1096 ) FAYETTE COUNTY ) HOUSING AUTHORITY and ) ANDRE WALTERS, ) ) Defendants. )

MEMORANDUM OPINION

This action is brought pursuant to 42 U.S.C. § 1983 by Plaintiff Jarrod Franty (“Plaintiff”) against his former employer, Fayette County Housing Authority (the “Housing Authority”), and Housing Authority Deputy Director Andre Walters (“Walters”), (collectively, “Defendants”). In his Second Amended Complaint, Plaintiff alleges that Defendants terminated his employment because of his political support of another individual, in violation of his rights under the First Amendment to the Constitution of the United States. Presently before the Court is Defendants’ Motion to Dismiss Plaintiff’s Second Amended Complaint (“Motion to Dismiss”) (Docket No. 34) and brief in support (Docket No. 35), and Plaintiff’s brief in opposition (Docket No. 39). For the reasons set forth herein, Defendants’ Motion to Dismiss will be granted. I. BACKGROUND1 Since the parties are well-acquainted with the factual background of this case, at this juncture the Court will present an abbreviated version of the facts alleged in the Second Amended Complaint that are relevant to the motion presently before the Court. Plaintiff was

1 Plaintiff contends that the Court has subject matter jurisdiction over this matter under 28 U.S.C. § 1331 and § 1343(3). (Docket No. 33, ¶ 3). formerly employed by the Housing Authority as a property manager. (Docket No. 33, ¶ 8). In that capacity, Plaintiff managed two properties. (Id. ¶ 9). In January of 2022, an apartment at one of those properties was abandoned and the former tenant left several items behind. (Id. ¶¶ 10, 11). In accordance with the Housing Authority’s policies and procedures, Plaintiff was to remove the tenant’s belongings from the apartment when it became vacant. (Id. ¶ 11). Via a

private Facebook message sent by Plaintiff to another individual, Plaintiff offered to sell some of the items that had been left behind. (Id. ¶ 13). Thereafter, on or about March 7, 2022, Plaintiff’s employment with the Housing Authority was terminated by Walters. (Id. ¶ 15). Walters informed Plaintiff that his discharge occurred as a direct result of his attempt to sell the abandoned items and his violation of the Housing Authority’s social media policy. (Id. ¶ 17). At the time of his discharge, Plaintiff’s uncle, Harry Joseph (“Joseph”) had recently, in or about February 2022, become the chairman of the Housing Authority’s board of directors. (Docket No. 33, ¶ 25). Plaintiff alleges that he has “openly supported” Joseph’s candidacy for chairman. (Id. ¶ 26). According to Plaintiff, an unnamed individual (who politically opposed

Joseph) reported Plaintiff’s private Facebook message to unnamed representatives of the Housing Authority (who were also politically opposed to Joseph), and Walters (who was also politically opposed to Joseph) terminated Plaintiff because of his political support for Joseph. (Id. ¶¶ 27-29). Additionally, according to Plaintiff, sometime after his discharge, two unnamed current employees of the Housing Authority told unnamed members of Plaintiff’s community that Plaintiff was “set up” by Walters as a direct result of his connection to Joseph. (Id. ¶ 30). Plaintiff also avers that Joseph was informed by an unnamed former Housing Authority employee that Plaintiff was “set up,” and that Plaintiff’s discharge was a direct result of his connection to Joseph. (Id. ¶ 31). The original Complaint in this matter named the Housing Authority as the sole defendant, and alleged claims of “Retaliation – Political Retaliation” and “Retaliation – Familial Association.” (Docket No. 1). After the Housing Authority moved to dismiss the Complaint (Docket Nos. 9, 10), Plaintiff sought leave to amend his claims (Docket No. 11), which the Court granted (Docket No. 13). Plaintiff filed his Amended Complaint, naming Walters as an

additional defendant, removing his claim of “Retaliation – Familial Association,” and including new claims of “Stigma Plus” and “Selective Enforcement” under the 14th Amendment. (Docket No. 16). In response, Defendants filed a motion to dismiss the Amended Complaint and supporting brief, Plaintiff filed an opposition brief, and Defendants filed a reply. (Docket Nos. 20, 21, 24, 27). The Court held oral argument on Defendants’ motion to dismiss the Amended Complaint, and granted Defendants’ motion pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted. (Docket Nos. 31, 32, 38). The Court dismissed all claims without prejudice to amendment, and advised Plaintiff that he would be afforded one final opportunity to amend his claims. (Id.).

Plaintiff filed a Second Amended Complaint alleging two Counts against Defendants: (1) “Retaliation – Political Retaliation” under the First Amendment; and (2) “Stigma Plus” under the Fourteenth Amendment. (Docket No. 33). Defendants have moved for a third time to dismiss Plaintiff’s claims. (Docket Nos. 34, 35). In response to Defendants’ third motion to dismiss, Plaintiff states that he “respectfully withdraws his ‘Stigma Plus’ claim at Count II.” (Docket No. 39 at 2 n.1). In accordance with Plaintiff’s request, his claim at Count II will be dismissed with prejudice, pursuant to Federal Rule of Civil Procedure 41(a)(2). Plaintiff further responds that he opposes Defendants’ motion to the extent it seeks dismissal of Count I of the Second Amended Complaint.2 As the motion has been fully briefed by the parties, it is now ripe for decision. II. STANDARD OF REVIEW In considering a Rule 12(b)(6) motion to dismiss, the factual allegations contained in the complaint must be accepted as true and must be construed in the light most favorable to the

plaintiff, and the court must “‘determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.’” Phillips v. County of Allegheny, 515 F.3d 224, 231 (3d Cir. 2008) (quoting Pinker v. Roche Holdings Ltd., 292 F.3d 361, 374 n.7 (3d Cir. 2002)); see Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 563 n.8 (2007). While Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the claim showing that the pleader is entitled to relief,” the complaint must “‘give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.’” Phillips, 515 F.3d at 231 (quoting Twombly, 550 U.S. at 555 (internal citation and quotation marks omitted)). Moreover, while “this standard does not require ‘detailed factual allegations,’” Rule 8 “demands more than an

unadorned, the-defendant-unlawfully-harmed-me accusation.” Id. (quoting Twombly, 550 U.S. at 555); Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 555).

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FRANTY v. FAYETTE COUNTY HOUSING AUTHORITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/franty-v-fayette-county-housing-authority-pawd-2025.