GLAVIN v. COMMONWEALTH OF PENNSYLVANIA

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 31, 2025
Docket2:24-cv-04904
StatusUnknown

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

Bluebook
GLAVIN v. COMMONWEALTH OF PENNSYLVANIA, (E.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA

ELLEN GLAVIN, : Plaintiff, : : v. : No. 24-cv-4904 : COMMONWEALTH OF : PENNSYLVANIA, et al., : Defendants. :

MEMORANDUM

Joseph F. Leeson, Jr. March 31, 2025 United States District Judge

In a prior Memorandum and Order, the Court dismissed the Complaint filed by Ellen Glavin brought pursuant to 42 U.S.C. § 1983 asserting constitutional violations. Glavin v. Commonwealth of Pennsylvania, No. 24-4904, 2024 WL 4338660 (Sept. 27, 2024). Her claims against the Commonwealth of Pennsylvania and State of New Jersey for money damages, and her claim for declaratory relief were dismissed with prejudice since any attempt to amend those claims were deemed to be futile. Her claim for injunctive relief was dismissed without prejudice to her reasserting those claims in newly filed habeas corpus petitions in each State in which she was convicted. To the extent that Glavin sought to raise excessive force claims against specific law enforcement officers involved with her arrest in Pennsylvania, she was granted leave to file an amended complaint in this case to raise those claims, however, she was directed to reassert any excessive force claim involving her New Jersey arrest, if at all, in an appropriate court in New Jersey. When Glavin failed to file an amended complaint within the time period permitted, the Court entered a final order of dismissal on December 23, 2024. (ECF No. 8.) On February 27, 2025, Glavin filed an untimely Amended Complaint (ECF No. 9) that largely ignored the Court’s directives. Nonetheless, because Glavin is proceeding pro se the Court will vacate the final order of dismissal.1 On statutory screening the Amended Complaint will be dismissed pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii). I. FACTUAL ALLEGATIONS

In her original Complaint Glavin asserted that she was cited in Pennsylvania for driving with a suspended license, had her vehicle impounded, and was later put into a pretrial intervention program resulting in a one-year term of supervised probation. (Compl. at 4.) Although she did not say when this happened, she asserted that unidentified officers involved in the vehicle stop used excessive force. (Id.) She also asserted that the imposition of supervised probation was disproportionate to the nature of her offense and violated her Eighth Amendment rights. (Id. at 5.) She claimed that a motion to modify her probation was denied despite her “exemplary conduct and full compliance.” (Id.) On April 17, 2023, Glavin was stopped for speeding in New Jersey. (Id.) She stated in

the original Complaint that she had “private plates” on the vehicle and “no updated license or registration.” (Id.) Her request during the stop to see a magistrate and for authorities to “produce an injured party” were denied. (Id.) Authorities smashed her driver’s side window, forcibly removed her from the vehicle, handcuffed, body searched, and arrested her. (Id.) She asserted that she spent two days in two different prisons prior to being placed in a pretrial

1 Glavin filed a “request for status update” (ECF No. 10) asserting she did not get “any updates” on her prior filing. It is possible that she did not receive the Court’s prior orders or failed to understand her obligation to file a timely amended complaint. Given the preference for resolution of cases on their merits, see Se. Pa. Transp. Auth. v. Orrstown Fin. Servs., Inc., 12 F.4th 337, 345 (3d Cir. 2021) (quoting T Mobile Ne. LLC v. City of Wilmington, 913 F.3d 311, 328 (3d Cir. 2019)), the Court will vacate the dismissal order. intervention program. (Id. at 6.) Glavin alleged that the New Jersey incident also involved excessive force and her sentence was disproportionate. (Id.) A subsequent motion to reduce her New Jersey penalty was also denied despite her compliance with the terms of her probation. (Id.) Glavin requested as relief for her claims that this Court exercise review of her state

convictions, seeking a de novo review of “judicial practices that have ratified police behaviors leading to constitutional violations.” (Id. at 10.) She also sought a declaration that her rights were violated, an injunction requiring the Defendants to terminate her supervised probation and expunge her record, and unstated compensatory damages. (Id. at 11-12.) Notwithstanding the above described limited scope granted Glavin to reassert claims in an amended complaint, she again named the Commonwealth and State of New Jersey, as well as John Doe Officers 1-5 and John Doe Supervisors 1-3.2 (Am. Compl. 3-4.) She seeks to assert claims under § 1983 “seeking judicial review and declaratory and injunctive relief for ongoing constitutional violations resulting from state court actions in Pennsylvania and New Jersey” and

raises excessive force, unlawful arrest, and malicious prosecution claims. (Id. at 2.) With regard to the Pennsylvania arrest, the date of which she again fails to state, she claims in conclusory terms only that she was subjected to excessive force by Pennsylvania officers during a traffic stop, that the officers “unreasonably escalated force” and acted inconsistently with their training and policy provisions. (Id. at 4.) She claims that being placed on supervised probation violated her due process rights, caused her undue hardship, and the “goal was to insulate wrongdoing and

2 Unless otherwise cited, the factual allegations set forth in this portion of the Memorandum are taken from Glavin’s Amended Complaint (ECF No. 9). The Court adopts the sequential pagination assigned to all pro se documents by the CM/ECF docketing system. to construe a case as facially legitimate and warranted that should have never existed.” (Id. at 5.) With regard to the April 17, 2023 New Jersey incident, she alleges that she had a non-consensual interaction with law enforcement, was forcibly removed from her vehicle, her window was smashed, she was handcuffed and body searched, detained for two days without cause, and placed in a pre-trial intervention program. (Id.)

Glavin alleges a Fourth Amendment excessive force claim against John Does Officers 1- 5 in their individual and official capacities but fails to differentiate the actions of any particular unknown Defendant, particularly whether the John Does were involved in the Pennsylvania or the New Jersey incident, or whether the John Does were state or municipal officials. (Id. at 5-6.) She asserts false arrest and malicious prosecution claims under the Fourteenth Amendment against John Doe Officers 1-5 and Supervisors 1-3 in their individual and official capacities, asserting the Officers violated her rights based on the arrests and probationary proceedings in the two states, and the Supervisors violated her rights based on their failures to prevent and correct the violations of the Officers. (Id. at 6.) As part of official capacity claims and to raise a separate Monell claim,3 she also alleges in conclusory fashion that municipal policies and

customs encouraged or failed to prevent violations of her rights (id. at 6) and that the failure to train “created an unconstitutional policy, practice, and protocol adopted as standard operating procedure leading to ongoing harm to [Glavin] and others similarly situated.” (Id.

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GLAVIN v. COMMONWEALTH OF PENNSYLVANIA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/glavin-v-commonwealth-of-pennsylvania-paed-2025.