Raymond Hall v. Pittsburgh Regional Transit

District Court, W.D. Pennsylvania·Decided July 17, 2026·No. 2:25-cv-01622·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA PITTSBURGH DIVISION RAYMOND HALL, ) ) ) Civil Action No.: ) 2:25-CV-01622-NBF-CBB Plaintiff, ) ) vs. ) Nora Barry Fischer ) Senior United States District Judge PITTSBURGH REGIONAL TRANSIT, ) ) ) Christopher B. Brown ) United States Magistrate Judge Defendant. )

REPORT AND RECOMMENDATION ON MOTION TO DISMISS ECF No. 12 Christopher B. Brown, United States Magistrate Judge I. Recommendation This civil action was initiated in this court on October 20, 2025, by pro se Plaintiff Raymond Hall (“Hall”). ECF No. 1. Hall alleges his employer, Defendant Pittsburgh Regional Transit (“PRT”), subjected him to race based discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000e, et seq. ECF No. 3. The Court has subject matter jurisdiction under 28 U.S.C. § 1331. Presently pending before the Court is PRT’s motion to dismiss for a more definite statement under Fed. R. Civ. P. 12(e) and alternatively for failure to state a claim under Fed. R. Civ. P. 12(b)(6). ECF No. 12. The motion is fully briefed and ripe for consideration. ECF Nos. 13, 18, 19. For the reasons that follow, it is respectfully recommended the Court grant PRT’s motion to dismiss for more definite statement under Fed. R. Civ. P. 12(e), dismiss Hall’s amended complaint

without prejudice and allow Hall to file a second amended complaint. It is further recommended if Hall is granted the opportunity to file a second amended complaint and fails to do so, that dismissal of his complaint be converted to dismissal with prejudice. Lastly, it is recommended PRT’s motion to dismiss for failure to state a claim be dismissed as moot and without prejudice to raise those arguments at a future procedural juncture.

II. Report a. Background Hall submits a two-page complaint and alleges he is “one of only a small

number of African American Wirepersons in the entire PRT system.” ECF No. 3 at ¶ 4.a. He claims after he filed “internal complaints” and “EEOC charges” of an unspecified nature, PRT “subjected [him] to accelerated discipline, repeated ‘105’ hearings and unwarranted written warnings” despite Hall presenting evidence to his supervisors that “his work was complete.” Id. at ¶¶ 4.b-c. Hall further alleges in August 2025, several supervisors instructed him and one other employee to “remove their tools and belongings from a shared workspace” but did not instruct other

employees to do the same. Id. at ¶ 4.d. He alleges “White wirepersons committing similar errors were not disciplined or were given lesser corrective actions” and his union representative did not file a grievance on his behalf. Id. at ¶ 4.e-f. It is on this basis Hall alleges PRT discriminated and retaliated against him in violation of Title VII.

Hall attached several documents related to his EEOC charges to his amended complaint. See ECF No. 3-1. Generally, these documents show that Hall filed an EEOC Charge at EEOC No. 533-2025-01637 (“First EEOC Charge”), the EEOC made no findings, and Hall received a Right to Sue Notice for the First EEOC Charge on July 22, 2025. Id. at 2-3. Hall then filed a subsequent EEOC Charge at EEOC No. 533-2025-03187 on September 9, 2025 alleging racial discrimination and

retaliation (“Second EEOC Charge”) from July 31-August 27, 2025. Id. at 6-7. In the Second EEOC Charge, Hall alleged before he filed the First EEOC Charge, he “had a clear work record” and after, he was subjected to “harassment and disciplinary actions which are unwarranted.” Id. at 6. According to Hall, the Second EEOC Charge remains pending. Id. at 1.

b. Standard of Review: Fed. R. Civ. P. 12(e) Motion for More Definite Statement and Pro Se Litigants Federal Rule of Civil Procedure 12(e) permits a party to “move for a more definite statement of a pleading to which a responsive pleading is allowed but which is so vague or ambiguous that the party cannot reasonably prepare a response.” Fed. R. Civ. P. 12(e). Rule 12(e) is part of the “district court’s case-management arsenal,” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 593 n. 13 (2007), that, in conjunction with the rest of Rule 12 and Rule 8, serves “to frame and govern [the] court's assessment of the quality of a pleading.” Sony BMG Music Ent. v. Cloud, No. CIV. 08-1200, 2008 WL 3895895, at *2 (E.D. Pa. Aug. 22, 2008). Generally speaking, “Rule 12(e) motions are disfavored in light of the liberal pleading standards established by Fed. R. Civ. P. 8(a).” Transp. Int'l Pool, Inc. v. Ross Stores, Inc., No. CIV. A. 06-1812, 2009 WL 1033601, at *2 (E.D. Pa. Apr. 15, 2009); see also

Country Classics at Morgan Hill Homeowners' Ass'n, Inc. v. Country Classics at Morgan Hill, LLC, 780 F. Supp. 2d 367, 371 (E.D. Pa. 2011) (“[M]otions for a more definite statement are ‘highly disfavored.’ ”). Thus, courts will grant a Rule 12(e) motion only “if a pleading is so vague or ambiguous that the opposing party cannot reasonably be required to make a responsive pleading.” Country Classics at Morgan Hill Homeowners' Ass'n, Inc., 780 F. Supp. 2d at 371 (internal quotations omitted).

Because Hall is proceeding pro se, the allegations in the Amended Complaint must be held to “less stringent standards than formal pleadings drafted by lawyers[.]” Haines v. Kerner, 404 U.S. 519, 520 (1972). If the Court can reasonably read the Amended Complaint to state a claim upon which relief can be granted, it will do so despite his failure to cite proper legal authority, confusion of legal

theories, poor syntax, and sentence construction, or unfamiliarity with pleading requirements. See Boag v. MacDougall, 454 U.S. 364 (1982). Despite this leniency, “pro se litigants still must allege sufficient facts in their complaints to support a claim.” Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 245 (3d Cir. 2013) (citing Riddle v. Mondragon, 83 F.3d 1197, 1202 (10th Cir. 1996)).

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