Logue v. The Unified Judicial System of Pennsylvania

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 14, 2025
Docket1:23-cv-00535
StatusUnknown

This text of Logue v. The Unified Judicial System of Pennsylvania (Logue v. The Unified Judicial System of Pennsylvania) 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
Logue v. The Unified Judicial System of Pennsylvania, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA JAMES F. LOGUE

Plaintiff, CIVIL ACTION NO. 1:23-CV-00535

v. (MEHALCHICK, J.)

YORK COUNTY COURT OF COMMON PLEAS,

Defendant.

MEMORANDUM Before the Court is a motion to dismiss filed by Defendant York County Court of Common Pleas (“York CCP”). (Doc. 50). This is a civil rights action initiated upon the filing of a complaint by Plaintiff James F. Logue (“Logue”) on March 27, 2023. In the operative second amended complaint, filed on April 22, 2024, Logue re-alleged that York CCP violated his civil rights under Title II of the Americans with Disabilities Act (“ADA”) and § 504 of the Rehabilitation Act (“RA”) by discriminating against him based upon his disability and added allegations of Fourteenth Amendment violations based upon York CCP’s denying Logue due process. (Doc. 46, at 14-15). On May 20, 2024, York CCP filed its motion to dismiss Logue’s second amended complaint. (Doc. 50). For the following reasons, York CCP’s motion to dismiss will be GRANTED. (Doc. 50). I. BACKGROUND AND PROCEDURAL HISTORY The following background is taken from Logue’s second amended complaint. (Doc. 46). Logue filed his second amended complaint on April 22, 2024. (Doc. 46). In his second amended complaint, Logue begins by re-alleging much of his previous allegations. (Doc. 46, ¶¶ 1-65). Logue suffers from alcohol use disorder (“AUD”). (Doc. 46, ¶ 8). Logue was pulled over and charged with a second DUI on May 18, 2020. (Doc. 46, ¶ 21). After his second DUI, Logue was given a SCRAM alcohol monitoring bracelet and applied for York CCP’s DUI Program. (Doc. 46, ¶¶ 27-28). Logue tested positive for alcohol on a random urine screening on August 11, 2022, just over a week before he was scheduled to graduate from the DUI Program on August 23,

2022. (Doc. 46, ¶¶ 34, 38-39). Logue denies that he drank alcohol and argues that his positive test resulted from a throat spray. (Doc. 46, ¶ 41). Due to the positive alcohol test, Logue was not permitted to graduate from the DUI Program as scheduled. (Doc. 46, ¶ 44). Logue requested that this decision be reconsidered, but Officer Forry, the lead Adult Probation/Parole Supervisor for the DUI Program denied the request. (Doc. 46, ¶¶ 14, 45). After failing to graduate from the DUI Program, Logue began reporting increases in anxiety and depression to the DUI Program team, which did not respond but referred him to a mental healthcare specialist. (Doc. 46, ¶¶ 46-49). On September 21, 2022, York County probation officers arrived at Logue’s home and

required that he take a breathalyzer test, which Logue admits to failing due to consumption of wine. (Doc. 46, ¶ 50). Officer Forry told Logue that he would not arrest him and would instead get a psychological referral in motion. (Doc. 46, ¶ 52). On September 23, 2022, Logue received an e-mail requiring Logue to report to court on September 28, 2022 based on his failed breathalyzer test. (Doc. 46, ¶ 54). Logue responded, copying Officer Forry, asking why he had not received a psychological consult referral, and later that day, Logue successfully scheduled a psychological evaluation on September 28, 2022. (Doc. 46, ¶¶ 55-57). Logue forwarded his evaluation results, which recommended immediate treatment, to Officer Forry. (Doc. 46, ¶ 59). When Logue arrived to his 4:00 PM DUI Court session, no judge was present. Instead, Officer Forry was present and informed Logue that he would be detained as a result of his failed breathalyzer test. (Doc. 46, ¶ 60). In his second amended complaint, Logue alleges for the first time that while incarcerated, Logue continued to express his intent to remain in the DUI Program and in DUI Court and “even reached out to the lead District Attorney of York County, David Sunday, a personal acquaintance, to see if he could offer

any assistance.” (Doc. 46, ¶¶ 65-68). Logue also alleges for the first time that County officials ignored his requests and that he was advised that “Defendants were not happy with Plaintiff because he ‘made too much noise.’” (Doc. 46, ¶¶ 67, 69). Logue was issued a probation violation due to his failed breathalyzer test and was told that “the only way that the probation team would let him out of jail was if he was willing to ‘waive’ his objection to York County probation’s recommendation of removal from DUI Court.” (Doc. 46, ¶¶ 70-72). Logue felt he had no choice and agreed. After being released, Logue spoke with the director of York County sobriety program, who expressed shock that he was not offered in-patient treatment as a “last resort” with the DUI Court Team, as that

was protocol. (Doc. 46, ¶ 74). At Logue’s probation hearing, Officer Forry recommended six months of incarceration in a county prison and additional six months of urine testing. (Doc. 46, ¶ 76). The District Attorney, meanwhile, “scoffed” at this recommendation and recommended only three months of “some sort of incarceration.” (Doc. 46, ¶ 77). The Judge ultimately ordered three months of house arrest and continuous SCRAM monitoring. (Doc. 46, ¶ 77). In the second amended complaint, Logue includes additional novel allegations that York County has discriminated against other individuals with disabilities. (Doc. 46, ¶ 81). He names five individuals who failed drug tests and were not permitted to continue in the DUI Program. (Doc. 46, ¶ 81). Logue also alleges that unlike himself, and the five individuals named, “younger participants of the DUI Court program were given chances of rehabilitation even after multiple positive alcohol/drug tests.” (Doc. 46, ¶ 82). Logue alleges for the first time that the older participants were “told things such as: grow up; you’re too old for this; and you can’t teach an old dog new tricks.” (Doc. 46, ¶ 84). Logue contends that he was

removed from the program due to personal animus and manifestation of his disability. (doc. 46, ¶ 85). Logue commenced this action by filing a complaint on March 27, 2023. He filed an an amended complaint on July 19, 2023, which was dismissed with leave to amend by Judge Rambo.1 (Doc. 44). Logue filed his operative second amended complaint on April 22, 2024, in which he includes nearly identical factual allegations.2 In his second amended complaint, Logue re-asserts his ADA and RA claim in Count I, without any additional allegations other than those outlined above, and asserts for the first time in Count II a Fourteenth Amendment violation for denial of due process by removing Logue from the DUI Program. (Doc. 46, at

14-15). On May 6, 2024, York CCP filed a motion to dismiss Logue’s complaint, and on May 20, 2024, filed a brief in support. (Doc. 50; Doc. 55). On June 17, 2024, Logue filed his brief in opposition. (Doc. 62). In his brief in opposition, Logue withdraws his claim for injunctive

1 In her dismissal, Judge Rambo notes that “Logue’s official capacity suit against Officer Forry is to be treated as against York CCP, who is already a party, and therefore the court will proceed to address the claim as brought against York CCP only.” (Doc. 44, at 1 n.1). Accordingly, this Court will once again address Logue’s claim as brought against York CCP only. See Ky. v. Graham, 473 U.S. 159, 166 (1985) (holding that an official capacity suit is treated as a suit against the entity “in all respects other than name”). 2 Any new allegation that Logue makes in his second amended complaint is pointed out in this factual summary. relief and withdraws his claim for age discrimination.3 (Doc. 62, at 21). The motion to dismiss is fully briefed and ripe for disposition. (Doc. 50; Doc. 55; Doc. 62). On August 30, 2024, this matter was reassigned to the undersigned district judge. II. LEGAL STANDARD FOR MOTION TO DISMISS

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