Jeremy Williams v. Cheryl Steberger; Denise Commings; and Jared Snader

CourtDistrict Court, E.D. Pennsylvania
DecidedJune 29, 2026
Docket5:26-cv-02622
StatusUnknown

This text of Jeremy Williams v. Cheryl Steberger; Denise Commings; and Jared Snader (Jeremy Williams v. Cheryl Steberger; Denise Commings; and Jared Snader) 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
Jeremy Williams v. Cheryl Steberger; Denise Commings; and Jared Snader, (E.D. Pa. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA ____________________________________

JEREMY WILLIAMS : Plaintiff, : : v. : No. 26-cv-2622 : CHERYL STEBERGER; : DENISE COMMINS; and : JARED SNADER, : Defendants. : ____________________________________

MEMORANDUM Joseph F. Leeson, Jr. June 29, 2026 United States District Judge Pro se Plaintiff Jeremy Williams filed this civil rights action while housed as a pretrial detainee at Lancaster County Prison. Williams claims that the Defendants conspired to set an excessive bail to ensure he remained in pretrial detention. Williams also seeks leave to proceed in forma pauperis. For the following reasons, the Court will grant Williams leave to proceed in forma pauperis and dismiss his Complaint in part with prejudice and in part without prejudice. I. FACTUAL ALLEGATIONS1 On November 12, 2025, Williams was charged with Burglary and Criminal trespass. (Compl. at 10.) After Williams was arrested on these charges, Defendant Lancaster County Detective Jared Snader sent “an ex parte letter” to Defendant Lancaster County Magisterial District Judge Denise Commins. (Compl. at 4) In the letter, Snader requested that cash bail be set at an amount Williams could not post ($500,000), citing Williams’s “significant flight risk”

1 The facts are taken from Williams’s Complaint (ECF No. 2). The Court adopts the pagination supplied by the CM/ECF docketing system. and “significant danger to his community.” (Id.) Snader stated that Williams’s criminal history was extensive, that Williams committed the burglary while high on methamphetamine, and that he believed Williams would have committed the burglary if the victim were present. (Id.) Snader also stated that Williams told him “he would leave Lancaster immediately once he was

able to.” (Id. at 18.) Williams alleges that he never told Snader that he would leave Lancaster. (Id. at 15.) Williams alleges that Snader’s ex parte communication to Judge Commins was intended to set the bail so high that Williams could not post it and would remain in pretrial detention. (Id.) At a preliminary arraignment hearing, his bail was set at $500,000. See Commonwealth v. Williams, CP-36-CR-0004917-2025 (C.P. Lancaster); Commonwealth v. Williams, MJ-02202-CR-0000486-2025 (M.J. Lancaster). Based on these allegations, Williams asserts Eighth and Fourteenth Amendment claims against Snader, Judge Commins, and Cheryl Steberger, the Warden at Lancaster County Prison who “accepted and maintained” Williams’s detention at the prison. (Id. at 4.) He also asserts conspiracy claims under 42 U.S.C. §§ 1983 and 1985(3), alleging that Defendants conspired to

set an excessive bail and discriminate against him on the basis of his lack of wealth. (Id. at 4, 12.) Williams requests damages, declaratory relief, and that he be released from pretrial detention and be ordered a new bail hearing.2 (Id. at 4.)

2 Williams asks the Court for a declaration that Defendants violated his constitutional rights. (Compl. at 16.) Williams’s claim for declaratory relief will be denied because it merely seeks to adjudicate past conduct, which is improper. See Corliss v. O’Brien, 200 F. App’x 80, 84 (3d Cir. 2006) (per curiam) (noting that a “[d]eclaratory judgment is inappropriate solely to adjudicate past conduct,” and is also not “meant simply to proclaim that one party is liable to another”); see also Taggart v. Saltz, No. 20-3574, 2021 WL 1191628, at *2 (3d Cir. Mar. 30, 2021) (per curiam) (“A declaratory judgment is available to define the legal rights of the parties, not to adjudicate past conduct where there is no threat of continuing harm.”). In addition, Williams’s public criminal docket reflects that he entered a negotiated guilty plea and was sentenced to prison time and a period of probation. Thus, Williams’s request that Defendants be ordered to release him from pretrial detention and grant him a new bail hearing is II. STANDARD OF REVIEW The Court grants Williams leave to proceed in forma pauperis because it appears that he is incapable of paying the fees to commence this civil action.3 Accordingly, 28 U.S.C. § 1915(e)(2)(B)(ii) requires the Court to dismiss the Complaint if it fails to state a claim. Whether

a complaint fails to state a claim under § 1915(e)(2)(B)(ii) is governed by the same standard applicable to motions to dismiss under Federal Rule of Civil Procedure 12(b)(6), see Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999), which requires the Court to determine whether the complaint contains “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations omitted). At the screening stage, the Court will accept the facts alleged in the pro se Complaint as true, draw all reasonable inferences in Williams’s favor, and “ask only whether that complaint, liberally construed, contains facts sufficient to state a plausible claim.” Shorter v. United States, 12 F.4th 366, 374 (3d Cir. 2021) (cleaned up), abrogation on other grounds recognized by Fisher v. Hollingsworth, 115 F.4th 197 (3d Cir. 2024). Conclusory allegations do not suffice. Iqbal, 556

U.S. at 678. As Williams is proceeding pro se, the Court construes his allegations liberally.

now moot. See Carlton v. Warden Atl. Cnty. Just. Facility, No. 22-1488, 2022 WL 4459910, at *1 (3d Cir. June 30, 2022) (“Appellant’s Speedy Trial claim challenging his pretrial detention has been rendered moot by his conviction”); Baker v. Warden Cumberland Cnty. Prison, No. 18- 3817, 2019 WL 2612772, at *1 (3d Cir. May 9, 2019) (“to the extent that Appellant has pleaded guilty, his claims pertaining to his pretrial detention have been rendered moot by his conviction”). Even if it were not moot, such relief cannot be granted in a civil action such as this one, brought pursuant to 42 U.S.C. § 1983. See Preiser v. Rodriguez, 411 U.S. 475, 500 (1973) (stating that when a prisoner “is challenging the very fact or duration of his physical imprisonment, and the relief he seeks is a determination that he is entitled to immediate release or a speedier release from that imprisonment, his sole federal remedy is a writ of habeas corpus”). 3 Because Williams is a prisoner, he will be obligated to pay the filing fee in installments in accordance with the Prison Litigation Reform Act. See 28 U.S.C. § 1915(b). Vogt v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021) (citing Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 244-45 (3d Cir. 2013)). III. DISCUSSION The Court understands Williams to assert Eighth Amendment excessive bail claims,

Fourteenth Amendment equal protection and due process claims, and conspiracy claims under 42 U.S.C. §§ 1983 and 1985(3).

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Jeremy Williams v. Cheryl Steberger; Denise Commings; and Jared Snader, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeremy-williams-v-cheryl-steberger-denise-commings-and-jared-snader-paed-2026.