Kieth E. Medash and Danielle Medash, Parents and Guardians of E.M.M., a minor v. County of Luzerne, Luzerne County Children, Youth & Families, Sherri Hartman, and Jessica Timek

CourtDistrict Court, M.D. Pennsylvania
DecidedMay 1, 2026
Docket3:25-cv-01732
StatusUnknown

This text of Kieth E. Medash and Danielle Medash, Parents and Guardians of E.M.M., a minor v. County of Luzerne, Luzerne County Children, Youth & Families, Sherri Hartman, and Jessica Timek (Kieth E. Medash and Danielle Medash, Parents and Guardians of E.M.M., a minor v. County of Luzerne, Luzerne County Children, Youth & Families, Sherri Hartman, and Jessica Timek) 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
Kieth E. Medash and Danielle Medash, Parents and Guardians of E.M.M., a minor v. County of Luzerne, Luzerne County Children, Youth & Families, Sherri Hartman, and Jessica Timek, (M.D. Pa. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA KIETH E. MEDASH and : DANIELLE MEDASH, Parents and Guardians of E.M.M., a : minor, Plaintiffs, CIVIL ACTION NO. 3:25-CV-1732

V. (JUDGE MANNION) COUNTY OF LUZERNE, LUZERNE COUNTY CHILDREN, : YOUTH & FAMILIES, SHERRI HARTMAN, and JESSICA TIMEK, : Defendants. : MEMORANDUM Defendants County of Luzerne, Luzerne County Children, Youth & Families, Sherri Hartman, and Jessica Timek (“Defendants”) present the Court with its motion to dismiss Plaintiffs Kieth E. Medash’s and Danielle Medash’s, guardians of E.M.M., a minor, (“Plaintiffs”) amended complaint for failure to state a claim upon which relief can be granted, and accompanying brief. (Docs. 16, 17). For the reasons set forth below, Defendants’ motion will be DENIED. i. BACKGROUND The underlying cause of action is brought before the Court pursuant to 42 U.S.C. §1983 for the injuries E.M.M., an infant, sustained while in his

natural parents’ custody. (Doc. 15). Plaintiff alleges that Andrew Carter and Brittany Cooper (collectively, “natural parents”) were known to Defendants due to their “extensive criminal history, noncompliance with court ordered services, and their significant involvement with Luzerne County Children Youth & Families for many years including the termination of parental rights of their prior children.” (Doc. 15 at 2-3). Andrew Carter, aged twenty-nine, has a “history of substance abuse and domestic violence as well as an extensive criminal history.” /d. at 10. Brittany Cooper, aged twenty, has a history of mental health diagnoses. /d. Both natural parents have been involved with the Luzerne County Drug Court. /d. According to Plaintiffs, the natural parents had two prior children removed from their care and parental rights terminated. Specifically, “[oJn August 31, 2018, the natural parents’ rights to one child were involuntarily terminated .. . On November 14, 2019, the natural mother . . . relinquished her parental rights to the other child [and]

... the natural father... had his parental rights to the other child involuntarily terminated.” /d. at 11. Plaintiffs are the adoptive parents and guardians of E.M.M. and E.M.M.’s two older siblings, who were removed from the natural parents’ custody after their parental rights were terminated. /d. at 5. Prior to E.M.M.’s birth, Plaintiff Danielle Medash notified Defendant Hartman that the natural

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parents were expecting a third child. /d. at 7. Danielle Madash was concerned that the natural parents were incapable of parenting, due in part to their inability to comply with court-ordered services related to their prior termination of parental rights. /d. at 7-8. On May 6, 2020, E.M.M. was born at Geisinger-GMC hospital. /d. at 3. Two days later, Defendants Hartman and Timek completed a preliminary assessment and scored the overall risk to E.M.M. as “high.” /d. At the time of the assessment, the natural parents had not completed court-ordered services “including parenting education, mental health evaluations, substance abuse services, and batterer’s intervention[,]’ which was allegedly Known to Defendants. /d. at 3-4. Plaintiffs allege that despite such knowledge, “Defendants affirmatively chose to forego an emergency shelter

care hearing and file a dependency petition.” /d. at 4. Nonetheless, Defendants determined that E.M.M. was “safe,” meaning that E.M.M. could “safely remain in the current living arrangement or with the caregiver(s) of origin.” /d. at 13. On May 13, 2020, Defendants created an initial service plan. /d. at 15. The next day, Defendant Timek filed a dependency petition. /d. The court scheduled an adjudicatory hearing for June 5, 2020. /d. On June 4, 2020, one day before the hearing, E.M.M. was brought to the Wilkes-Barre

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emergency department and subsequently transferred to Geisinger Wyoming Valley because he was listless. /d. at 16. “E.M.M. had severe and significant brain damage with decreasing levels of consciousness, at least three skull fractures, suspected seizures, and a healing jaw fracture . . . [t]he cause of these injuries was determined to be abusive brain trauma.” /d. at 16. Andrew Carter was arrested for physical abuse of E.M.M. and pleaded guilty to related charges. /d. at 17. He was sentenced to serve 60-120 months of incarceration followed by a period of probation. /d. Plaintiffs commenced the underlying action on September 16, 2025. (Doc. 1). After Defendants filed a motion to dismiss the complaint, Plaintiffs filed an amended complaint with jury demand. (Docs. 12, 15). On December 12, 2025, Defendants filed the immediate “motion to dismiss the amended complaint” and brief in support. (Docs. 16, 17). Plaintiffs filed their brief in opposition to Defendants’ motion on December 29, 2025. (Doc. 18). Defendant filed a reply brief on January 12, 2026. (Doc. 20). This matter is now ripe for disposition. ll. LEGAL STANDARD The Federal Rules of Civil Procedure require that a complaint contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed.R.Civ.P. 8(a)(2). This standard “does not require detailed

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factual allegations, but it demands more than an unadorned, the-defendant- unlawfully-harmed me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal quotations omitted). A complaint that contains only “labels and conclusions,” or a “formulaic recitation of the elements of a cause of action” does not comply with Rule 8. /d. A defendant may move to dismiss a complaint “for failure to state a claim upon which relief can be granted.” Fed. R. Civ. P. 12(b)(6). The moving party bears the burden of showing that no claim has been stated, and dismissal is appropriate only if, accepting all the facts alleged in the complaint as true, the plaintiff has failed to plead “enough facts to state a claim to relief that is plausible on its face.” Hedges v. United States, 404 F.3d 744, 750 (3d Cir. 2005); Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (abrogating “no set of facts” language found in Conley v. Gibson, 355 U.S. 41, 45-46 (1957)). The facts alleged must be sufficient to “raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. This requirement “calls for enough fact[s] to raise a reasonable expectation that discovery will reveal evidence of’ necessary elements of the plaintiff's cause of action. /d. “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on

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its face.” Iqbal, 556 U.S. at 678. Facial plausibility is achieved “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” /d. Plausibility does not require probability but “more than a sheer possibility that

a defendant has acted unlawfully.” /d. Facts “merely consistent with” liability do not satisfy this standard. /d. As noted above, the Court at this stage accepts the complaint’s factual allegations as true. This tenet “is inapplicable to legal conclusions.” /d.

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Kieth E. Medash and Danielle Medash, Parents and Guardians of E.M.M., a minor v. County of Luzerne, Luzerne County Children, Youth & Families, Sherri Hartman, and Jessica Timek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kieth-e-medash-and-danielle-medash-parents-and-guardians-of-emm-a-pamd-2026.