KANAPESKY v. TOWNSHIP OF EAST BRANDYWINE

CourtDistrict Court, E.D. Pennsylvania
DecidedJuly 23, 2025
Docket2:24-cv-06520
StatusUnknown

This text of KANAPESKY v. TOWNSHIP OF EAST BRANDYWINE (KANAPESKY v. TOWNSHIP OF EAST BRANDYWINE) 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
KANAPESKY v. TOWNSHIP OF EAST BRANDYWINE, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Matthew Kanapesky, Plaintiff, CIVIL ACTION v. NO. 24-6520 Township of East Brandywine, et al., Defendants. Pappert, J. July 23, 2025 MEMORANDUM Matthew Kanapesky sued the Township of East Brandywine, alleging that (1) the Township violated his First Amendment and equal protection rights by causing police officers to harass him and prosecute him for theft, and (2) the theft prosecution constituted an abuse of process under Pennsylvania law. The Township moves to dismiss for failure to state a claim, and the Court grants the motion because Kanapesky has not alleged any basis for Monell liability. The Court also declines to exercise supplemental jurisdiction over the abuse-of-process claim and will not permit Kanapesky to further amend his Complaint.

I Kanapesky filed this suit in December 2024, alleging various violations of his constitutional rights by the Township and its employees dating as far back as 2019. See generally (Compl., ECF No. 1); (Am Compl., ECF No. 12.) Kanapesky has now largely abandoned his original claims. The current iteration of his Complaint names only the Township as a defendant and seeks recovery only for alleged rights violations that occurred after the initial complaint was filed. (Second Am. Compl. ¶¶ 5, 86, 114, 121, ECF No. 23.) Specifically, Kanapesky’s Complaint now focuses on a series of interactions he had with Township police in April of 2025. On April 15, Kanapesky “observed a

fisherman trespassing” on his land. (Id. ¶ 35.) The alleged trespasser was fishing in the Brandywine Creek, part of which Kanapesky says he owns. (¶¶ 18–19, 36.) Kanapesky instructed the fisherman to leave, but the fisherman refused and became angry, so Kanapesky called 911. (Id. ¶¶ 41, 43–44.) At some point, Kanapesky also “placed [the fisherman’s tacklebox] inside a trashcan.” (Id. ¶ 53.) Township Police Officer Christopher Fox responded to the 911 call. (Id. ¶ 46.) The first thing Officer Fox did when he arrived was argue with Kanapesky about some of the allegations contained in the First Amended Complaint in this action. (Id. ¶¶ 46– 49.) Only after the argument did Fox speak with the trespasser, who apparently “admitted to everything.” (Id. ¶ 52.) Officer Fox “t[ook] no action against the

trespasser,” except to tell him that he was “not getting [his] [tackle]box back.” (Id. ¶¶ 53–54.) Kanapesky asked Fox why the trespasser couldn’t have his tacklebox back and Fox responded by “yell[ing]” at Kanapesky, “dismiss[ing] his concerns” and stating “that the matter was closed.” (Id. ¶ 54.) That evening, however, Fox returned to Kanapesky’s house with Officers Brendan Flood and Ryan Eastman and demanded that Kanapesky return the tacklebox, or else they would charge him with theft. (Id. ¶¶ 57–65.) Kanapesky asked Fox why he’d changed his tune and then asked to speak to a superior officer with his lawyer present. (Id. ¶ 66.) The officers ignored his questions and left without the tacklebox. (Id. ¶¶ 67, 77.) The following day, Kanapesky attempted to speak with Deputy Chief Jeffrey Yankanich about the prior day’s events. (Id. ¶ 68.) Yankanich told Kanapesky over the

phone that he was busy, but Kanapesky nevertheless went to the Township police station to speak with him face-to-face. (Id. ¶¶ 69–70.) Yankanich was “combative” when Kanapesky arrived, and he told Kanapesky that an “affidavit of probable cause had already been submitted to the magistrate,” so Kanapesky would have to take up his grievances in court. (Id. ¶¶ 71–72.) A couple weeks later, on May 1, Kanapesky received by mail a criminal complaint charging him with theft. (Id. ¶¶ 71, 73, Ex. H.) Eastman is the officer who submitted the affidavit of probable cause in support of the charges. (Id. ¶ 73.) II To avoid dismissal for failure to state a claim under Rule 12(b)(6), a complaint

must contain facts sufficient to state a claim that is facially “plausible.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is facially plausible when the factual allegations permit a court to make the reasonable inference that the defendant is liable for the alleged misconduct. Id. The “mere possibility of misconduct” is not enough; the complaint “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Id. at 678–79 (quoting Twombly, 550 U.S. at 570). Determining plausibility is a “context-specific task” requiring a court to use its “judicial experience and common sense.” Connelly v. Lane Constr. Corp., 809 F.3d 780, 786–87 (3d Cir. 2016). In making this determination, the court assumes well-pleaded facts are true, construes those facts in the light most favorable to the plaintiff, and draws reasonable inferences from them. Id. at 790. The plaintiff need only allege enough facts to “raise a reasonable expectation that discovery will reveal evidence” of

each element of his claim. Connelly, 809 F.3d, at 788–89. But “[c]onclusory assertions of fact and legal conclusions” are not entitled to the presumption of truth. Schuchardt v. President of the United States, 839 F.3d 336, 347 (3d Cir. 2016). So “[a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). III A Section 1983 permits individuals to sue for violations of their federal rights. 42 U.S.C. § 1983. But pursuant to Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (1978), a municipality like East Brandywine may only be held liable under § 1983 if it was the

“moving force” behind the rights violation. Hightower v. City of Philadelphia, 130 F.4th 352, 356 (3d Cir. 2025) (quoting Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 691, 694 (1978)). That is, a municipality is not vicariously liable for violations of federal rights by its employees. Id. at 355. A plaintiff may satisfy the “moving force” requirement in one of two ways. First, the plaintiff can show that his injuries were proximately caused by an “unconstitutional policy or custom of the municipality.” Forrest v. Parry, 930 F.3d 93, 105 (3d Cir. 2019) (citation omitted). A policy is “an official proclamation, policy or edict by a decisionmaker possessing final authority to establish municipal policy on the relevant subject.” Id. at 105. And a custom is a “course of conduct so well-settled and permanent as to virtually constitute law.” Id. at 105–06. Second, a plaintiff may show that his injuries were caused by a “failure or inadequacy by the municipality” that amounts to “deliberate indifference to the

constitutional rights of those affected.” Id. at 105–06. A plaintiff taking the deliberate- indifference route must show that municipal policymakers were on notice that their failure to act would result in frequent rights violations and yet failed to act anyway. Id. at 106; Hightower, 130 F.4th at 357.

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Related

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371 U.S. 178 (Supreme Court, 1962)
Monell v. New York City Dept. of Social Servs.
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Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
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G. Jang v. Boston Scientific SciMed Inc
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Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Schuchardt v. President of the United States
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Bluebook (online)
KANAPESKY v. TOWNSHIP OF EAST BRANDYWINE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kanapesky-v-township-of-east-brandywine-paed-2025.