LINS v. PENNSYLVANIA SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS

CourtDistrict Court, E.D. Pennsylvania
DecidedJune 23, 2023
Docket5:21-cv-03975
StatusUnknown

This text of LINS v. PENNSYLVANIA SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS (LINS v. PENNSYLVANIA SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS) 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
LINS v. PENNSYLVANIA SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS, (E.D. Pa. 2023).

Opinion

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

SETH LINS, : : Plaintiff, : CIVIL ACTION NO. 21-3975 : v. : : PENNSYLVANIA SOCIETY FOR THE : PREVENTION OF CRUELTY TO : ANIMALS; NICOLE WILSON, : individually and in her official capacity; : LISA GERMANIS, VMD, individually and : in her official capacity; JENNIFER : NIELDS, Humane Society Police Officer; : and DOES 1 to 10, : : Defendants. :

MEMORANDUM OPINION Smith, J. June 23, 2023 This case involves a former puppy mill owner suing an animal welfare organization and its employees over the treatment of his dogs on the day that said organization seized them. The paramount issue before the court is whether certain surrender and release forms signed by the plaintiff exculpate the defendants from liability in this case. The court ultimately finds that they do and therefore grants summary judgment in the defendants’ favor. In September 2019, the defendant organization executed a search warrant of the plaintiff’s property after receiving reports of multiple dogs suffering from unsanitary conditions and health issues. Said organization seized the plaintiff’s dogs and transported them away in vans. Due to a malfunctioning air conditioner in one of the vans, some of the dogs suffered from heat stroke and at least one died. Nevertheless, during the seizure, the plaintiff signed a surrender and release form which, among other things, stated that the plaintiff agreed to release the defendants from any claim or loss “arising out of the negotiation or execution of this agreement, the removal of any animal subject to this release or the transfer of ownership of the within animal(s) to the [organization].” Following the seizure, the plaintiff pleaded guilty to numerous counts related to him running the puppy mill. As a condition of his plea, the plaintiff signed another surrender and release form near-

identical to the one he signed on the day of the seizure. Months later, the plaintiff was again investigated after suspicions arose of him engaging in similar illegal activities. During this investigation, his computers were seized and allegedly damaged after being subjected to forensic examination. The plaintiff brought this action against the defendants in September 2021. His amended complaint—the operative complaint in this matter—contained six counts: (1) Fourth Amendment unreasonable seizure of Lins’ dogs, (2) Fourth Amendment unreasonable seizure (Monell), (3) Fourteenth Amendment due process, (4) Fourteenth Amendment due process (Monell), (5) Fourth Amendment unreasonable seizure of computers and files, and (6) negligence. The defendants have now motioned for summary judgment on all counts. Specifically, the defendants assert that the

surrender and release forms signed by the plaintiff shield them from liability in this case. Alternatively, the defendants argue that all counts raised by the plaintiff fail as a matter of law. For the reasons laid out in this opinion, the court must properly grant the defendants’ motion. To begin, the court finds the release clause within the surrender and release forms to be enforceable as it relates to each of the plaintiff’s claims. Regarding his constitutional claims, the court finds that (1) the plaintiff voluntarily signed the forms, and (2) the forms are relevant to the public interest. Regarding his state law claim, the court finds that at least the second form satisfies the elements of a contract under Pennsylvania law. Accordingly, the forms exculpate the defendants from the plaintiff’s present suit. Furthermore, even if there were no release, the court would still enter summary judgment for the defendants on Counts II through V. First, the plaintiff’s Monell claims—Counts II and IV—fail because he has identified no policies or customs that have caused his alleged injuries. Moreover, the plaintiff’s due process claims—Counts III and IV—are improperly raised, as he had adequate post-deprivation due process afforded to him, namely state-

law remedies (e.g., conversion). Finally, the plaintiff has effectively abandoned Count V by not responding to the defendants’ arguments regarding the count in either his response brief or sur- replies. Consequently, given these findings, the court must enter judgment in the defendants’ favor on all counts. I. PROCEDURAL HISTORY On September 3, 2021, the plaintiff, Seth Lins (“Lins”), initiated this action pro se by filing a complaint against the Pennsylvania Society for the Prevention of Cruelty to Animals (“PSPCA”), Nicole Wilson (“Wilson”), Lisa Germanis (“Germanis”), Jennifer Nields (“Officer Nields”), and “Does 1 to 10.”1 See Doc. No. 2. Wilson and Germanis were sued in both their individual and official capacities. See id. The complaint alleged that the defendants committed animal cruelty against dogs owned by Lins, ultimately resulting in the deaths of some. The complaint contained

nine counts: (1) Fourth Amendment unreasonable seizure of Lins’ dogs, (2) Fourth Amendment unreasonable seizure—illegal official policy or custom, (3) Fourth Amendment unreasonable search and seizure of Lins’ dogs—ratification of illegal actions, (4) Fourth Amendment unreasonable seizure of dogs—custom or tolerance of acquiescence, (5) Fourth Amendment failure to turn and supervise, (6) Fourteenth Amendment due process, (7) Fourteenth Amendment due process—illegal official policy or custom, (8) Fourteenth Amendment due process—custom or tolerance of acquiescence, and (9) Fourteenth Amendment due process—failure to train and

1 Lins filed pro se specifically “with the intention of finding local counsel.” Compl. at 2, Doc. No. 2. supervise. See Compl. at 16–36. Counts II through V and VII through IX were brought exclusively against the PSPCA. See id. at 17–29, 31–36. Count VI was brought exclusively against Officer Nields and the Does. See id. at 29–31. All counts were brought pursuant to section 1983.2 On November 4, 2021, the defendants filed a motion to dismiss the complaint. See Doc. No. 9. On December 17, 2021, local counsel filed a notice of appearance on behalf of Lins.3 See

Doc. No. 14. The court subsequently issued an order permitting Lins to file an amended complaint. See Doc. No. 19. Lins filed his amended complaint—the operative complaint in this case—on February 17, 2022. See Doc. No. 20. The amended complaint named the same defendants as the original complaint but only contained six counts: (1) Fourth Amendment unreasonable seizure of Lins’ dogs, (2) Fourth Amendment unreasonable seizure (Monell), (3) Fourteenth Amendment due process, (4) Fourteenth Amendment due process (Monell), (5) Fourth Amendment unreasonable seizure of computers and files, and (6) negligence.4 See Am. Compl. at ¶¶ 152–262, Doc. No. 20. The defendants answered the amended complaint on March 3, 2022, which they subsequently amended a day later. See Doc Nos. 22, 24.

2 Under section 1983,

[e]very person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress . . . .

42 U.S.C. § 1983. Because the PSPCA acted in this case as an entity “statutorily authorized to enforce Pennsylvania laws pertaining to criminal cruelty-to-animals violations,” it can be subject to liability under section 1983. Allen v. Pa. Soc’y for the Prevention of Cruelty to Animals, 488 F. Supp. 2d 450, 462 (M.D. Pa. 2007).

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Bluebook (online)
LINS v. PENNSYLVANIA SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lins-v-pennsylvania-society-for-the-prevention-of-cruelty-to-animals-paed-2023.