Katrina S. Ferguson v. City of Philadelphia Department of Human Services, et al.

CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 26, 2026
Docket2:25-cv-06419
StatusUnknown

This text of Katrina S. Ferguson v. City of Philadelphia Department of Human Services, et al. (Katrina S. Ferguson v. City of Philadelphia Department of Human Services, et al.) 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
Katrina S. Ferguson v. City of Philadelphia Department of Human Services, et al., (E.D. Pa. 2026).

Opinion

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

KATRINA S. FERGUSON, : Plaintiff, : : v. : CIVIL ACTION NO. 25-CV-6419 : CITY OF PHILADELPHIA : DEPARTMENT OF HUMAN : SERVICES, et al., : Defendants. :

MEMORANDUM BEETLESTONE, C.J. JANUARY 26 , 2026 Katrina S. Ferguson filed this pro se civil rights action alleging claims under § 1983, the Americans with Disabilities Act (“ADA”)/Rehabilitation Act (“RA”), and state tort law, based on the loss of custody of her minor daughter.1 Ferguson seeks leave to proceed in forma pauperis. For the following reasons, leave to proceed in forma pauperis will be granted and the Complaint will be dismissed. I. FACTUAL ALLEGATIONS2 Ferguson names the following Defendants in her Complaint: (1) the City of Philadelphia Department of Human Services (“DHS”); (2) Tyrie J. Sealy; (3) Case Worker Carl Tyndle; (4) Supervisor Aquila Lewis-Uqdah; (5) Administrator Vivan Smalls; (6) Supervisor Shanelle

1 The Court notes that Ferguson’s Complaint bears the heading, “In the Court of Common Pleas, Philadelphia County, Pennsylvania.” (Compl. at 1-2.) To the extent she intended to file this action in state court, Ferguson may voluntarily dismiss this action and refile in that venue. See Fed. R. Civ. P. 41(a)(1)(A)(i).

2 The factual allegations are taken from Ferguson’s Complaint, which consists of four typewritten pages and two letters from the Department of Veterans Affairs, attached as exhibits. (ECF No. 2.) The Court considers the entirety of the submission to constitute the Complaint and adopts the sequential pagination assigned by the CM/ECF docketing system. McCleary; (7) Administrator Commissioner Kimberly Ali; and (8) Chief of Staff Katherine Garzon. (Compl. at 1.) Ferguson’s allegations appear to stem from dependency proceedings in the Philadelphia County Court of Common Pleas. She alleges that on May 30, 2024, DHS employees removed her minor daughter from her custody without a warrant or court order, and

in spite of Ferguson having a valid custody order granting her parenting time with her child. (Id. ¶¶ 3-4.) She asserts that the Defendants “falsely attributed a diagnosis of schizophrenia to Plaintiff, despite her actual diagnosis being Bipolar 1 disorder with anxiety, confirmed by licensed medical providers.” (Id. ¶ 5.) The DHS Defendants did not review Ferguson’s medical records, contact her medical providers, or afford her a hearing or notice before revoking her parental rights. (Id. ¶ 6.) She alleges that DHS took custody of her daughter even though “no court has terminated or suspended her parental rights.” (Id. ¶ 7.) As a result of these events, Ferguson alleges she was forced to pay $800 per month in child support, suffered severe emotional distress, humiliation, reputational harm, and financial hardship. (Id. ¶ 8.) Ferguson brings claims under the Fourteenth Amendment due process and

equal protection clauses, the ADA/RA, and state law tort claims. (Id. at 1-4.) She seeks money damages, restoration of her parental rights, costs and attorney’s fees. (Id.) II. STANDARD OF REVIEW The Court grants Ferguson leave to proceed in forma pauperis because it appears that she is incapable of paying the fees to commence this civil action. 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); Talley v. Wetzel, 15 F.4th 275, 286 n.7 (3d Cir. 2021). At this early stage of the litigation, the Court will accept the facts alleged in the pro se complaint as true, draw all reasonable inferences in the

plaintiff’s favor, and ask only whether the complaint contains facts sufficient to state a plausible claim. See Shorter v. United States, 12 F.4th 366, 374 (3d Cir. 2021), 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. Because Ferguson is proceeding pro se, the Court construes her allegations liberally. 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)). The Court will “apply the relevant legal principle even when the complaint has failed to name it.” Id. However, “pro se litigants still must allege sufficient facts in their complaints to support a claim.” Id. (quoting Mala, 704 F. 3d at 245). An unrepresented litigant “cannot flout procedural rules — they must abide by the same rules that

apply to all other litigants.” Id. In that regard, a complaint may be dismissed for failing to comply with Federal Rule of Civil Procedure 8. Garrett v. Wexford Health, 938 F.3d 69, 91 (3d Cir. 2019). Rule 8 requires a pleading to include a “short and plain statement showing that the pleader is entitled to relief,” as well as a statement of the court’s jurisdiction and a demand for the relief sought. Fed. R. Civ. P. 8(a). “This standard operates in tandem with that of Rule 10,” which requires that a pleading contain a caption with the Court’s name and the names of the parties, and that claims be listed in numbered paragraphs. Fabian v. St. Mary’s Med. Ctr., No. 16-4741, 2017 WL 3494219, at *3 (E.D. Pa. Aug. 11, 2017) (citing Fed. R. Civ. P. 10). In determining whether a pleading meets Rule 8’s “plain” statement requirement, the Court should “ask whether, liberally construed, a pleading ‘identifies discrete defendants and the actions taken by [the named] defendants’ in regard to the plaintiff’s claims.” Garrett, 938 F.3d at 93 (citation omitted). “Naturally, a pleading that is so vague or ambiguous that a defendant cannot reasonably be expected to

respond to it will not satisfy Rule 8.” Id. (cleaned up). The important consideration for the Court is whether, “a pro se complaint’s language . . . presents cognizable legal claims to which a defendant can respond on the merits.” Id. at 94. The Court must also review the pleadings and dismiss the matter if it determines that the action fails to set forth a proper basis for this Court’s subject matter jurisdiction. Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”); Group Against Smog and Pollution, Inc. v. Shenango, Inc., 810 F.3d 116, 122 n.6 (3d Cir. 2016) (explaining that “an objection to subject matter jurisdiction may be raised at any time [and] a court may raise jurisdictional issues sua sponte”). A plaintiff commencing an action in federal court bears the burden of establishing federal jurisdiction. See

Lincoln Ben. Life Co. v. AEI Life, LLC, 800 F.3d 99, 105 (3d Cir. 2015) (citing DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 n.3 (2006)). III. DISCUSSION A.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

§ 1915
28 U.S.C. § 1915
§ 12132
42 U.S.C. § 12132
§ 794
29 U.S.C. § 794
§ 12102
42 U.S.C. § 12102
§ 12131
42 U.S.C. § 12131
§ 1367
28 U.S.C. § 1367
§ 1332
28 U.S.C. § 1332

Cite This Page — Counsel Stack

Bluebook (online)
Katrina S. Ferguson v. City of Philadelphia Department of Human Services, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/katrina-s-ferguson-v-city-of-philadelphia-department-of-human-services-paed-2026.