Rahman v. Foster Township

CourtDistrict Court, M.D. Pennsylvania
DecidedJune 24, 2025
Docket3:24-cv-01615
StatusUnknown

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Bluebook
Rahman v. Foster Township, (M.D. Pa. 2025).

Opinion

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

FARIDA RAHMAN, : CIVIL NO. 3:24-CV-1615 : Plaintiff, : : v. : : (Magistrate Judge Carlson) FOSTER TOWNSHIP, : : Defendant. :

MEMORANDUM OPINION

I. Factual Background This case comes before us for consideration of a motion to dismiss (Doc. 22) which challenges the legal sufficiency of the plaintiff’s pro se amended complaint. (Doc. 14). That amended complaint is a largely incomprehensible pleading which demands a great deal of the reader. The pleading begins with a non sequitur, the plaintiff’s averment that: “Defendant always used state officials to help him win cases.” (Doc. 14, ¶¶1, 2). What then follows are a series of grudges and complaints regarding sewer service which entail events which allegedly took place between 2011 and 2021. (Id., ¶¶ 3-6). Rahman then seems to allude to dissatisfaction in the outcome of some state court litigation. (Id., ¶¶7-13). Following this recital, the amended complaint ends without any clear or identifiable prayer for relief. (Id.) Presented with this amended complaint, the defendant, Foster Township, has moved to dismiss the complaint, arguing that Rahman’s pleading failed as a matter

of law. (Doc. 22). This motion is fully briefed1 and is, therefore, ripe for resolution. Accordingly, for the reasons that follow, the motion to dismiss will be granted. II. Discussion

A. Motion to Dismiss – Standard of Review A motion to dismiss tests the legal sufficiency of a complaint. It is proper for the court to dismiss a complaint in accordance with Rule 12(b)(6) of the Federal Rules of Civil Procedure only if the complaint fails to state a claim upon which relief

can be granted. Fed. R. Civ. P. 12(b)(6). With respect to this benchmark standard for the legal sufficiency of a complaint, the United States Court of Appeals for the Third Circuit has aptly noted the evolving standards governing pleading practice in federal

court, stating that: Standards of pleading have been in the forefront of jurisprudence in recent years. Beginning with the Supreme Court’s opinion in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), continuing with our opinion in Phillips [v. County of Allegheny, 515 F.3d 224, 230 (3d Cir. 2008)], and culminating recently with the Supreme Court’s decision in

1 There has been a somewhat haphazard aspect to the briefing of this motion, which is now closed. The defendant filed a brief in support of the motion on May 30, 2025. (Doc. 24). We then ordered a response by Rahman.(Doc. 25). In response, Rahman initially stated that she had not received the defendant’s pleadings. (Dc. 26). Accordingly, we instructed the defendant to file proof of service upon the plaintiff, which it did on June 12, 2025. (Doc. 28). We then allowed Rahman until June 23, 2025 to file a further substantive response. (Doc. 29). This deadline has now elapsed without further action on Rahman’s part. Ashcroft v. Iqbal, BU.S.B, 129 S. Ct. 1937 (2009), pleading standards have seemingly shifted from simple notice pleading to a more heightened form of pleading, requiring a plaintiff to plead more than the possibility of relief to survive a motion to dismiss.

Fowler v. UPMC Shadyside, 578 F.3d 203, 209-10 (3d Cir. 2009). In considering whether a complaint fails to state a claim upon which relief may be granted, the court must accept as true all allegations in the complaint and all reasonable inferences that can be drawn therefrom are to be construed in the light most favorable to the plaintiff. Jordan v. Fox, Rothschild, O’Brien & Frankel, Inc., 20 F.3d 1250, 1261 (3d Cir. 1994). However, a court “need not credit a complaint’s bald assertions or legal conclusions when deciding a motion to dismiss.” Morse v. Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997). Additionally, a court

need not “assume that a . . . plaintiff can prove facts that the . . . plaintiff has not alleged.” Associated Gen. Contractors of Cal. v. California State Council of Carpenters, 459 U.S. 519, 526 (1983). As the Supreme Court held in Bell Atlantic

Corp. v. Twombly, 550 U.S. 544 (2007), in order to state a valid cause of action, a plaintiff must provide some factual grounds for relief which “requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of actions will not do.” Id., at 555. “Factual allegations must be enough to raise a right

to relief above the speculative level.” Id. In keeping with the principles of Twombly, the Supreme Court has underscored that a trial court must assess whether a complaint states facts upon which relief can be granted when ruling on a motion to dismiss. In Ashcroft v. Iqbal, 556 U.S. 662 (2009), the Supreme Court held that, when considering a motion to

dismiss, a court should “begin by identifying pleadings that, because they are no more than conclusions, are not entitled to the assumption of truth.” Id., at 679. According to the Supreme Court, “[t]hreadbare recitals of the elements of a cause of

action, supported by mere conclusory statements, do not suffice.” Id., at 678. Rather, in conducting a review of the adequacy of a complaint, the Supreme Court has advised trial courts that they must: [B]egin by identifying pleadings that because they are no more than conclusions are not entitled to the assumption of truth. While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations. When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.

Id., at 679.

Thus, following Twombly and Iqbal, a well-pleaded complaint must contain more than mere legal labels and conclusions; it must recite factual allegations sufficient to raise the plaintiff’s claimed right to relief beyond the level of mere speculation. As the United States Court of Appeals for the Third Circuit has stated: [A]fter Iqbal, when presented with a motion to dismiss for failure to state a claim, district courts should conduct a two-part analysis. First, the factual and legal elements of a claim should be separated. The District Court must accept all of the complaint’s well-pleaded facts as true, but may disregard any legal conclusions. Second, a District Court must then determine whether the facts alleged in the complaint are sufficient to show that the plaintiff has a “plausible claim for relief.” In other words, a complaint must do more than allege the plaintiff’s entitlement to relief. A complaint has to “show” such an entitlement with its facts.

Fowler, 578 F.3d at 210-11.

As the court of appeals has observed: The Supreme Court in Twombly set forth the “plausibility” standard for overcoming a motion to dismiss and refined this approach in Iqbal. The plausibility standard requires the complaint to allege “enough facts to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570, 127 S. Ct. 1955.

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