Jaziah Strickland v. Nancy L. Butts, et al.

CourtDistrict Court, M.D. Pennsylvania
DecidedMay 19, 2026
Docket3:26-cv-00238
StatusUnknown

This text of Jaziah Strickland v. Nancy L. Butts, et al. (Jaziah Strickland v. Nancy L. Butts, et al.) 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
Jaziah Strickland v. Nancy L. Butts, et al., (M.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA JAZIAH STRICKLAND, ; No. 3:26-CV-0238 | Plaintiff | : (Judge Munley)

| NANCY L. BUTTS, et al., Defendants :

: MEMORANDUM Plaintiff Jaziah Strickland initiated the above-captioned pro se action under 42 U.S.C. § 1983, alleging constitutional violations during his arrest and pretrial detention at Lycoming County Prison. The court will dismiss Strickland’s complaint pursuant to 28 U.S.C. § 1915A(b)(1) for failure to state a claim upon which relief may be granted. | I. BACKGROUND Strickland’s complaint concerns his arrests in 2024 and 2025 and his pretrial detention at Lycoming County Prison during the pendency of his criminal cases. (See generally Doc. 1). He first alleges that Lycoming County Court of Common Pleas Judge Nancy L. Butts approved a search warrant for his residence without probable cause. (See id. at 4, 6). He then claims that

| 1 Section 1983 creates a private cause of action to redress constitutional wrongs committed by | state officials. The statute is not a source of substantive rights; it serves as a mechanism for vindicating rights otherwise protected by federal law. See Gonzaga Univ. v. Doe, 536 U.S. 273, | 284-85 (2002).

| Detective Tyson Havens and the Narcotics Enforcement Unit (NEU)— presumably of Lycoming County—improperly executed the warrant by breaking down his front door, tearing his home apart, and destroying his personal | property. (Id. at 4).

| Strickland next alleges that he was held in pretrial detention at Lycoming

| County Prison for 16 months while awaiting trial, and during that detention he | was subjected to unconstitutional conditions of confinement. (Id. at 4-5). He avers that he was confined in the “SMU” for approximately two months, and his | cell in the SMU was cold, covered in feces and old food residue, and smelled of “old urine.” (Id. at 5). After being released from the SMU, he was transferred to the “DLU,” where he was subjected to constant lighting for 22 out of 24 hours of the day, causing sleep deprivation, visual hallucinations, and depression. (ld.) | He alleges that he was held in the DLU for eleven months but does not indicate | how long he was subjected to the near-constant illumination. (Id.) He further | claims that he successfully filed a grievance to address the lighting issue. (Id.) | Strickland recounts that he was released on bail in August 2025, but arrested again on November 7, 2025, for “posting a music video with a fake prop | gun.” (Id.) He alleges that Detective Havens conducted another “unlawful” | search (presumably of Strickland’s residence), during which inculpatory evidence

was obtained that Strickland describes as “poisonous fruit.” (Id.) Detective

Havens later arrested Strickland on a warrant while Strickland was driving in his fiancé’s car with his fiancé and his one-year-old child. (Id. at 6). Strickland asserts that Detective Havens performed an illegal search of the car after | unlawfully coercing his fiance to consent to a vehicle search. (Id.) This vehicle

| search likewise turned up inculpatory evidence that resulted in criminal charges | against Strickland. (Id.) Although Strickland’s complaint is unclear about timing, he alleges that | Magisterial District Judge Aaron Biichle signed a second search warrant for a firearm that had been found in a purse during a search based on a warrant that

| did not include a firearm. (Id.) He appears to allege that the firearm was

| unlawfully obtained before Magisterial District Judge Biichle signed the second search warrant that permitted seizure of the weapon. (Id. at 6, 7). Strickland | alleges that he was charged with possession of this firearm based on this recovered gun. (ld. at 6). | Strickland sues Judge Butts, Magisterial District Judge Biichle, Detective | Havens, the Lycoming County NEU, and Lycoming County. (See id. at 2-3). He asserts Section 1983 claims invoking the Fourth, Fifth, Eighth, and Fourteenth Amendments. (See id. at 8). His complaint, however, fails to state a claim for | relief, so it will be dismissed.

lll. ©STANDARD OF REVIEW Courts are statutorily obligated to review, “as soon as practicable,” | unrepresented prisoner complaints targeting governmental entities, officers, or | employees. See 28 U.S.C. § 1915A(a). One basis for dismissal at the screening | stage is if the complaint “fails to state a claim upon which relief may be | granted[.]” Id. § 1915A(b)(1). This language closely tracks Federal Rule of Civil | Procedure 12(b)(6). Accordingly, courts apply the same standard to screening a | pro se prisoner complaint for sufficiency under Section 1915A(b)(1) as they | utilize when resolving a motion to dismiss under Rule 12(b)(6). See Grayson v. | Mayview State Hosp., 293 F.3d 103, 109-10 & n.11 (3d Cir. 2002); O’Brien v. U.S. Fed. Gov't, 763 F. App’x 157, 159 & n.5 (3d Cir. 2019) (per curiam) | (nonprecedential); cf. Allah v. Seiverling, 229 F.3d 220, 223 (3d Cir. 2000). | In deciding a Rule 12(b)(6) motion to dismiss, courts should not inquire | “whether a plaintiff will ultimately prevail but whether the claimant is entitled to | offer evidence to support the claims.” Scheuer v. Rhodes, 416 U.S. 232, 236 | (1974); see Nami v. Fauver, 82 F.3d 63, 66 (3d Cir. 1996). The court must

| accept as true the factual allegations in the complaint and draw all reasonable inferences from them in the light most favorable to the plaintiff. See Phillips v.

| County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). In addition to the facts

| alleged on the face of the complaint, the court may also consider “exhibits

| attached to the complaint, matters of public record, as well as undisputedly : authentic documents” attached to a defendant’s motion to dismiss if the □□□□□□□□□□□ claims are based upon these documents. Mayer v. Belichick, 605 F.3d 223, 230 (3d Cir. 2010) (citing Pension Benefit Guar. Corp. v. White Consol. Indus., 998

| F.2d 1192, 1196 (3d Cir. 1993)). When the sufficiency of a complaint is challenged, the court must conduct a aeote inquiry. See Connelly v. Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal citations and quotation marks omitted) (footnote omitted). At | step one, the court must “tak[e] note of the elements [the] plaintiff must plead to state a claim.” Id. (quoting Ashcroft v. Iqbal, 556 U.S. 662, 675 (2009) | (alterations in original)). Second, the court should distinguish well-pleaded factual allegations—which must be taken as true—from mere legal conclusions, which “are not entitled to the assumption of truth” and may be disregarded. ld. (quoting Iqbal, 556 U.S. at 679). Finally, the court must review the presumed- truthful allegations “and then determine whether they plausibly give rise to an | entitlement to relief.” Id. (quoting Iqbal, 556 U.S. at 679). Deciding plausibility is

a “context-specific task that requires the reviewing court to draw on its judicial | experience and common sense.” Iqbal, 556 U.S. at 681. | Because Strickland proceeds pro se, his pleadings are to be liberally

|} construed and his complaint, “however inartfully pleaded, must be held to less

stringent standards than formal pleadings drafted by lawyers[.]” Erickson v.

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