Merkeema Yvette Smalls v. Judge Betsy Jo Wahl, et al.

CourtDistrict Court, E.D. Pennsylvania
DecidedDecember 2, 2025
Docket2:25-cv-04852
StatusUnknown

This text of Merkeema Yvette Smalls v. Judge Betsy Jo Wahl, et al. (Merkeema Yvette Smalls v. Judge Betsy Jo Wahl, 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
Merkeema Yvette Smalls v. Judge Betsy Jo Wahl, et al., (E.D. Pa. 2025).

Opinion

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

MERKEEMA YVETTE SMALLS, : Plaintiff, : : v. : CIVIL ACTION NO. 25-CV-4852 : JUDGE BETSY JO WAHL, et al., : Defendants. :

MEMORANDUM Pappert, J. December 2, 2025 Pro se plaintiff Merkeema Yvette Smalls commenced this action by filing a complaint pursuant to 42 U.S.C. § 1983 asserting violations of her constitutional rights arising from state court child custody proceedings concerning her minor child L.S. Smalls subsequently filed her Motion for Leave to Proceed In Forma Pauperis (Dkt. No. 83) and Amended Complaint,1 (Amended Complaint (Dkt. No. 10), in which she asserts

1 An amended complaint, once submitted to the Court, serves as the governing pleading in the case because an amended complaint supersedes the prior pleading. See Shahid v. Borough of Darby, 666 F. App’x 221, 223 n.2 (3d Cir. 2016) (per curiam) (“Shahid’s amended complaint, however, superseded his initial complaint.” (citing W. Run Student Hous. Assocs. LLC v. Huntingdon Nat’l Bank, 712 F.3d 165, 171 (3d Cir. 2013)); see also Garrett v. Wexford Health, 938 F.3d 69, 82 (3d Cir. 2019), cert. denied, 140 S. Ct. 1611 (2020) (“In general, an amended pleading supersedes the original pleading and renders the original pleading a nullity. Thus, the most recently filed amended complaint becomes the operative pleading.”) (internal citations omitted); see also Argentina v. Gillette, 778 F. App’x 173, 175 n.3 (3d Cir. 2019) (holding that “liberal construction of a pro se amended complaint does not mean accumulating allegations from superseded pleadings”).

Smalls has also filed numerous documents on the docket. To the extent these submissions include factual allegations or relevant exhibits, they cannot be considered at this time, because the Federal Rules of Civil Procedure do not contemplate piecemeal pleadings or the amalgamation of pleadings, even in the context of a pro se litigant. See Bryant v. Raddad, No. 21-1116, 2021 WL 2577061, at *2 (E.D. Pa. June 22, 2021) (“Allowing a plaintiff to file partial amendments or fragmented supplements to the operative pleading, ‘presents an undue risk of piecemeal litigation that precludes orderly resolution of cognizable claims.’” (quoting Uribe v. Taylor, No. 10-2615, 2011 WL 1670233, claims against Judge Betsy Jo Wahl, Nefertiti C. Jordan, Esquire, and Mikal Coleman.2 For the following reasons, the Court will grant Smalls leave to proceed in forma pauperis.3 Smalls’s federal claims will be dismissed with prejudice for failure to state a claim pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii). Her state law claims will be dismissed

without prejudice for lack of subject matter jurisdiction, but without leave to amend. I4 Smalls, who resides in North Carolina, alleges that she is the “lawful mother and custodian” of the minor child, L.S. (AC at 2, 3.) Mikal Coleman is the child’s father, and the Court infers that he shares custody of the child with Smalls. (Id. at 2.) The Court further infers that Smalls seeks to amend the current custody arrangement because she believes her child is at risk while in Coleman’s care. She alleges that “CPS, hospital, Duke Health records, and photographic evidence confirm the child’s ongoing endangerment through vaping, firearm exposure, and emotional abuse.” (Id. at 3.)

at *1 (E.D. Cal. May 2, 2011)); Brooks-Ngwenya v. Bart Peterson’s the Mind Tr., No. 16-193, 2017 WL 65310, at *1 (N.D. Ind. Jan. 6, 2017) (“Piecemeal pleadings cause confusion and unnecessarily complicate interpretation of a movant’s allegations and intent[] . . . .”).

2 Also pending are the following: Emergency Motion and Petition for Temporary Restraining Order (Dkt. No. 9), Motion to Take Judicial Notice (Dkt. No. 12), Petition for Equitable Protective Relief (Dkt. No. 20), and Emergency Judicial Notice and Petition for Temporary Restraining Order (Dkt. No. 69). In light of the Court’s disposition of Smalls’s Amended Complaint, these motions and petitions will be denied as moot.

3 After filing her first Motion for Leave to Proceed In Forma Pauperis, Smalls filed two additional Motions for Leave to Proceed In Forma Pauperis that contain the same information as the first. (See Dkt. Nos. 92, 95.) These Motions will be denied as moot.

4 The factual allegations set forth in this Memorandum are taken from Smalls’s Amended Complaint. (Dkt. No. 10). The Court adopts the pagination supplied by the CM/ECF docketing system. Where appropriate, grammar, spelling, and punctuation errors in Smalls’s pleadings will be corrected for clarity. Judge Wahl, who is presiding over the custody proceedings, has allegedly stated on the record that she would “only change the custody order if [Smalls] moved back to Pennsylvania.” (Id.) Smalls accuses Judge Wahl of participating in ex parte communications, though she does not describe the contents of those communications

nor the participants, and attributes the Judge’s apparent disinclination to change the current custody arrangements to bias, though she does not describe any conduct, other than unfavorable rulings, that would indicate bias. (Id.) Smalls also alleges that Coleman’s counsel, Defendant Jordan, has misrepresented facts, violated her duty of candor, and obstructed service. (Id.) Smalls does not identify which facts have been misrepresented and provides no examples of a lack of candor or incident of obstruction of service on Jordan’s part. Smalls claims that the Defendants, acting together, have deprived her of custody of her child and have curtailed her parental rights. (Id.) Smalls asserts violations of her Fourteenth Amendment rights, claiming that the

Philadelphia Court of Common Pleas lacks jurisdiction over the pending custody matter under the UCCJEA.5 She also claims that the Defendants engaged in mail tampering and obstruction in violation of 18 U.S.C. §§ 1341 and 1505;6 and asserts violations of

5 The Court understands Smalls to refer to the Uniform Child Custody Jurisdiction and Enforcement Act, 23 Pa. Stat. and Cons. Stat. §5401, et seq. “The UCCJEA, 23 Pa.C.S.A. § 5401, et seq., was promulgated by the National Conference of Commissioners on Uniform State Laws in 1997 and became effective in Pennsylvania in 2004. . . . One of the main purposes of the UCCJEA was to clarify the exclusive, continuing jurisdiction for the state that entered the child custody decree. See 23 Pa.C.S.A. § 5422, cmt.; see also Bouzos–Reilly v. Reilly, 980 A.2d 643, 645 (Pa. Super. Ct. 2009).” Rennie v. Rosenthol, 995 A.2d 1217, 1220 (Pa. Super. Ct. 2010).

6 Criminal statutes generally do not give rise to a basis for civil liability. See Brown v. City of Philadelphia Office of Human Res., 735 F. App’x 55, 56 (3d Cir. 2018) (per curiam) (“Brown alleges that the defendants violated various criminal statutes, but most do not provide a private cause of action.”); Brown v. U.S. Dist. Ct. for the E. Dist. of Pa., No. 18-747 (E.D. Pa.) (Apr. 9, 2018 Order at 6 (dismissing claims under 18 U.S.C. § 1589 as “meritless and frivolous”)), aff’d, 740 F. App’x 239, 240 (3d Cir. 2018) (per curiam); Brown v. Progressive Specialty Ins. Co., 763 F. App’x 146, 147 (3d Cir.

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Merkeema Yvette Smalls v. Judge Betsy Jo Wahl, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/merkeema-yvette-smalls-v-judge-betsy-jo-wahl-et-al-paed-2025.