Fry v. Adams

CourtDistrict Court, D. Delaware
DecidedMarch 17, 2025
Docket1:24-cv-00491
StatusUnknown

This text of Fry v. Adams (Fry v. Adams) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fry v. Adams, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

ERIC ROBERT FRY, ) ) Plaintiff, ) ) v. ) C.A. No. 24-491-CFC-EGT ) MEGAN ADAMS et al., ) ) Defendants. )

REPORT AND RECOMMENDATION

Plaintiff Eric Robert Fry, an inmate at Howard R. Young Correctional Institution, filed this action pursuant to 42 U.S.C. § 1983. (D.I. 3). Plaintiff appears pro se and has been granted leave to proceed in forma pauperis. (D.I. 5). The Court proceeds to screen the Complaint pursuant to 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(a). For the reasons set forth below, the Court recommends that the Complaint be DISMISSED WITH PREJUDICE. I. BACKGROUND According to the Complaint, on January 31, 2024, Plaintiff was brought into one of his hearings after it had already begun. (D.I. 3 at 5). Plaintiff alleges that, at the time he came in, Judge Megan Adams was presiding, Detective Daniel Watson was testifying, and Deputy Attorney General James Betts and Public Defender John Edinger Jr. were also present. (Id.). All are named defendants in this case. When Plaintiff was brought into the hearing, he was seated next to Mr. Edinger as the hearing was concluding. (Id.). Plaintiff inquired as to what was happening, and he was allegedly told to be quiet. (Id.). Judge Adams “rule[d] on the case” shortly after Detective Watson finished testifying. (Id.). Plaintiff was then removed from the courtroom. (Id.). On April 8, 2024, Plaintiff voiced his concerns to Mr. Edinger about his rights being violated at this January 2024 hearing, and Mr. Edinger allegedly responded that he did not care about Plaintiff’s rights. (D.I. 3 at 6). Plaintiff further alleges that the four named Defendants participated in a conspiracy to violate his rights at the aforementioned hearing. (Id. at 5-6). Plaintiff requests that these four individuals “be held accountable.” (Id. at 8). II. LEGAL STANDARDS A federal court may properly dismiss an action sua sponte under the screening provisions

of 28 U.S.C. §§ 1915(e)(2)(B) and 1915A if “the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief.” Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013) (quotation marks omitted); see also 28 U.S.C. § 1915(e)(2) (in forma pauperis actions); 28 U.S.C. § 1915A (civil actions filed by prisoners seeking redress from governmental entities or government officers and employees). The Court must accept all factual allegations in a complaint as true and view them in the light most favorable to a pro se plaintiff. See Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). Because Plaintiff proceeds pro se, his pleading is 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).

A complaint is not automatically frivolous because it fails to state a claim. See Dooley v. Wetzel, 957 F.3d. 366, 374 (3d Cir. 2020). Rather, a claim is deemed frivolous only where it relies on an “‘indisputably meritless legal theory’ or a ‘clearly baseless’ or ‘fantastic or delusional’ factual scenario.’” Id. The legal standard for dismissing a complaint for failure to state a claim pursuant to §§ 1915(e)(2)(B)(ii) and 1915A(b)(1) is identical to the legal standard used when ruling on Rule 12(b)(6) motions. Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). Before dismissing a complaint or claims for failure to state a claim upon which relief may be granted pursuant to the screening provisions of §§ 1915 and 1915A, however, the Court must grant Plaintiff leave to amend his complaint unless amendment would be inequitable or futile. See Grayson v. Mayview State Hosp., 293 F.3d 103, 114 (3d Cir. 2002). A well-pleaded complaint must contain more than mere labels and conclusions. See Ashcroft v. Iqbal, 556 U.S. 662 (2009); Bell Ad. Corp. v. Twombly, 550 U.S. 544 (2007). A

plaintiff must plead facts sufficient to show that a claim has substantive plausibility. See Johnson v. City of Shelby, 574 U.S. 10, 12 (2014). A complaint may not be dismissed, however, for imperfect statements of the legal theory supporting the claim asserted. See id. at 11. A court reviewing the sufficiency of a complaint must take three steps: (1) take note of the elements the plaintiff must plead to state a claim; (2) identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth; and (3) when there are well- pleaded factual allegations, assume their veracity and then determine whether they plausibly give rise to an entitlement to relief. Connelly v. Lane Constr. Corp., 809 F.3d 780, 787 (3d Cir. 2016). Elements are sufficiently alleged when the facts in the complaint “show” entitlement to relief. Iqbal, 556 U.S. at 679 (quoting FED. R. CIV. P. 8(a)(2)). Determining whether a claim is plausible

is a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. III. DISCUSSION A. Judicial Immunity Plaintiff has sued Judge Adams, the judge who presided over Plaintiff’s hearing on January 31, 2024. “A judicial officer in the performance of his duties has absolute immunity from suit and will not be liable for his judicial acts.” Azubuko v. Royal, 443 F.3d 302, 303 (3d Cir. 2006). A judge may be deprived of this immunity only if they “acted in the ‘clear absence of all jurisdiction.’” Stump v. Sparkman, 435 U.S. 349, 357 (1978) (quoting Bradley v. Fisher, 80 U.S. 335, 351 (1871)). Plaintiff does not plead any facts to plausibly suggest that Judge Adams acted in the clear absence of all jurisdiction. (See D.I. 3). And the Court does not believe any such facts exist, particularly given that Judge Adams was presiding over Plaintiff’s hearing in a judicial capacity. Judge Adams is immune from suit and the Court recommends that the claims against

her be dismissed as frivolous pursuant to §§ 1915(e)(2)(B)(i) & (iii) and 1915A(b)(1) & (2). See Newton v. City of Wilmington, 206 F. Supp. 3d 947, 954 (D. Del. 2016), aff’d, 676 F. App’x 106 (3d Cir. 2017). B.

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Related

Bradley v. Fisher
80 U.S. 335 (Supreme Court, 1872)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Briscoe v. LaHue
460 U.S. 325 (Supreme Court, 1983)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Williams v. Hepting
844 F.2d 138 (Third Circuit, 1988)
Dawn Ball v. Famiglio
726 F.3d 448 (Third Circuit, 2013)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Sye Newton v. City of Wilmington
676 F. App'x 106 (Third Circuit, 2017)
Casey Dooley v. John Wetzel
957 F.3d 366 (Third Circuit, 2020)
Sincavage v. Barnhart
171 F. App'x 924 (Third Circuit, 2006)

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Fry v. Adams, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fry-v-adams-ded-2025.