HARRISON-EL v. BUCKS COUNTY CRIMINAL JUSTICE CENTER

CourtDistrict Court, E.D. Pennsylvania
DecidedFebruary 20, 2025
Docket2:24-cv-00413
StatusUnknown

This text of HARRISON-EL v. BUCKS COUNTY CRIMINAL JUSTICE CENTER (HARRISON-EL v. BUCKS COUNTY CRIMINAL JUSTICE CENTER) 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
HARRISON-EL v. BUCKS COUNTY CRIMINAL JUSTICE CENTER, (E.D. Pa. 2025).

Opinion

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

ALI A. HARRISON-EL, : Plaintiff, : : v. : CIVIL ACTION NO. 24-CV-0413 : BUCKS COUNTY : CRIMINAL JUSTICE CENTER, et al., : Defendants. :

MEMORANDUM GALLAGHER, J. FEBRUARY 20, 2025 Currently before the Court is a Motion for Reconsideration filed pro se by Plaintiff Ali. A. Harrison-El, a convicted prisoner who is currently incarcerated at SCI Phoenix. (“Motion” (ECF No. 12.)) The Motion seeks reconsideration of this Court’s June 24, 2024 Order, which dismissed Harrison-El’s claims with prejudice when he did not timely file an amended complaint. (See ECF No. 11.) A proposed Amended Complaint is attached to the Motion. (See ECF No. 12 at 3-13.) In his proposed Amended Complaint, Harrison-El asserts claims against the Bristol Township Police Department, Bristol Township Police Officers Kevin J. Jackson, Jennifer R. Jacker, and Kyle McKenna, and nine unnamed Bristol Township Police Officers. (Id. at 4-5.) He asserts his claims against the persons he has named as Defendants in their individual and official capacities. (Id.) For the following reasons, the Court will grant Harrison-El’s Motion for Reconsideration, deem his Amended Complaint filed, and direct that it be separately docketed. The Court will again dismiss Harrison-El’s request for vacatur of his convictions and release from confinement without prejudice to Harrison-El filing a habeas corpus petition. Harrison-El’s claims against the Bristol Township Police Department, his official capacity claims against the individual Defendants, and his individual capacity claims against Jackson and Jacker will be dismissed with prejudice for failure to state a claim. Harrison-El’s Fourth Amendment malicious prosecution claim will again be dismissed without prejudice for failure to state a claim. He will not be permitted to amend this claim at this time. Rather, he may file a new civil action to reassert this claim if his underlying convictions or sentences are ever reversed, vacated, or otherwise invalidated. Harrison-El’s state

law claims will be dismissed without prejudice for lack of subject matter jurisdiction, but without further leave to amend. Harrison-El’s claims against McKenna and the nine unidentified Bristol Township police officers will be dismissed without prejudice for failure to state a claim. Harrison- El will be granted leave to file a second amended complaint to address his claims against these Bristol Township Police Officers. I. PROCEDURAL HISTORY In his original Complaint, Harrison-El asserted claims arising from state court criminal proceeding during which he alleged he was illegally sentenced to two terms of imprisonment. See Harrison-El v. Bucks Cnty. Crim. Justice Cntr., No. 24-0413, 2024 WL 1976549, at *2 (E.D. Pa. May 3, 2024). He asserted both individual and official capacity claims against the individual

Defendants. Id. at *1. As relief, he requested that his convictions be overturned and his sentences vacated, that he not be subject to further probation or parole supervision, and that he be awarded money damages. Id. at *2. Upon screening, the Court dismissed with prejudice Harrison-El’s claims against the Bucks County Justice Center, his official capacity claims against the individual Defendants, and his individual capacity claims against Bucks County Court of Common Pleas Judge Charissa J. Liller and Bucks County District Attorney Matthew D. Wientraub for failure to state a claim. Id. at *7. Harrison-El’s Fourth Amendment malicious prosecution claim, and his Sixth Amendment speedy trial claim were dismissed without prejudice for failure to state a claim and without leave to amend, but with leave to file a new civil action reasserting those claims if his underlying convictions or sentences were ever reversed, vacated, or otherwise invalidated. Id. His individual capacity claims against Bristol Township Police Officers Jackson and Jacker were dismissed without prejudice for failure to state a claim, and his related state law claims were dismissed for lack of subject matter jurisdiction. Id. He was granted leave to file an amended

complaint addressing his claims against Jackson and Jacker, and his state law claims. Id. When Harrison-El did not file an amended complaint within the time permitted, the Court entered an Order dismissing his constitutional claims with prejudice and his state law claims without prejudice for lack of subject matter jurisdiction, but without further leave to amend. (See June 24, 2024 Order, ECF No. 11.) On July 15, 2024, Harrison-El filed the instant Motion, which is ripe for review. II. MOTION FOR RECONSIDERATION Since a final judgment has been entered in this case, the Court will construe Harrison-El’s pending motion as a conjoined motion for reconsideration and for leave to file an amended complaint.1 See Lacey v. City of Newark, 828 F. App’x 146, 150 (3d Cir. 2020) (per curiam)

(“A post-judgment motion to amend a complaint is properly construed as either a motion pursuant to Rule 59(e) or Rule 60(b) of the Federal Rules of Civil Procedure, depending upon when it was filed.” (citing Burtch v. Milberg Factors, Inc., 662 F.3d 212, 230 (3d Cir. 2011))). “[W]hen a timely motion to amend the complaint is filed under Rule 59(e), ‘the Rule 15 and 59 inquiries turn on the same factors,’ and leave to amend must be assessed for ‘undue delay, bad faith, prejudice to the opposing party, or futility.’” Lacey, 828 F. App’x at 150 (quoting Jang v. Boston Sci. Scimed, Inc., 729 F.3d 357, 367-68 (3d Cir. 2013)). “Therefore, the fact that the amended pleading

1 Harrison-El’s motion was filed within 28 days of the entry of the Order dismissing his case, and is, therefore, a timely filed motion for reconsideration under Federal Rule of Civil Procedure 59(e). offered by the movant will not cure the defects in the original pleading that resulted in the judgment of dismissal may be a valid reason both for denying [amendment and reconsideration].” See Ahmed v. Dragovich, 297 F.3d 201, 209 (3d Cir. 2002); see also Jang, 729 F.3d at 368. Upon reviewing the proposed AC, the Court will grant Harrison-El’s Motion and, for the following

reasons, dispose of the claims as described above. III. FACTUAL ALLEGATIONS2 The allegations in Harrison-El’s original Complaint arose from the January 17, 2024, courtroom proceedings that resulted in Harrison-El’s conviction and imprisonment. See Harrison- El, 2024 WL 1976549 at *2. The claims asserted in the AC appear to arise from events that occurred in 2020, during the period December 31, 2022 through January 20, 2023, and during the period February 14, 2023 through April 26, 2023. (AC at 7.) During those time periods, Defendants Jackson and Jacker allegedly filed false police reports, fabricated evidence and detained Harrison-El based on the allegedly false evidence. (Id.) They also allegedly participated in a conspiracy to fraudulently convict Harrison-El on unidentified criminal charges. (Id.)

Defendant McKenna and nine unidentified Bristol Township police officers allegedly participated in the conspiracy, and in furtherance of the conspiracy, allegedly committed perjury, assaulted Harrison-El, attempted homicide and the infliction of serious bodily injury upon him, and sought to cover up this conduct. (Id.) As a result of this conduct, Harrison-El alleges that he has been deprived of his liberty and his due process rights, and has experienced physical, mental, and

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HARRISON-EL v. BUCKS COUNTY CRIMINAL JUSTICE CENTER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harrison-el-v-bucks-county-criminal-justice-center-paed-2025.