Reid v. Munley

CourtDistrict Court, M.D. Pennsylvania
DecidedOctober 6, 2025
Docket1:25-cv-00844
StatusUnknown

This text of Reid v. Munley (Reid v. Munley) 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
Reid v. Munley, (M.D. Pa. 2025).

Opinion

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

DWAYNE A. REID, JR., : CIVIL ACTION NO. 1:25-CV-844 : Plaintiff : (Judge Neary) : v. : : MONICA M. LITTMAN, et al., : : Defendants :

MEMORANDUM

This is a civil rights case filed pursuant to 42 U.S.C. § 1983. Plaintiff, Dwayne A. Reid, Jr., alleges that three judges of this district and two lawyers violated his civil rights through actions they took in another civil case pending in this district, Reid v. Portfolio Recovery Associates, LLC, No. 1:24-CV-2101 (M.D. Pa. filed Dec. 5, 2024). The claims against the judges have been dismissed sua sponte. The claims against the lawyers will likewise be dismissed sua sponte. I. Factual Background & Procedural History

Reid filed this case on May 13, 2025. (Doc. 1). On July 18, 2025, the court dismissed the claims against the judges with prejudice and ordered plaintiff to show cause why the claims against the attorneys should not be dismissed, noting that it appeared that the attorneys had not acted under color of state law and that even if they had acted under color of state law, their actions could not be construed as violating plaintiff’s civil rights in any manner. (Docs. 29-30). Plaintiff responded to the court’s order on August 15, 2025. (Doc. 31). Plaintiff largely ignores the court’s order to state why the claims against the attorneys should not be dismissed, but he asserts several arguments for reconsideration of the dismissal of the claims against the judges. (Id.) His arguments are considered below. II. Legal Standard

The district court may sua sponte dismiss a claim for failure to state a claim upon which relief may be granted pursuant to Federal Rule of Civil Procedure 12(b)(6) after service of process if the court first gives the plaintiff notice and an opportunity to respond. See Grayson v. Mayview State Hosp., 293 F.3d 103, 111 n.15 (3d Cir. 2002); Oatess v. Sobolevich, 914 F.2d 428, 430 n.5 (3d Cir. 1990). In considering whether to dismiss a complaint for failure to state a claim upon which relief may be granted, the court must “accept all factual allegations as

true, construe the complaint in the light most favorable to the plaintiff, and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.” Phillips v. County of Allegheny, 515 F.3d 224, 233 (3d Cir. 2008) (quoting Pinker v. Roche Holdings, Ltd., 292 F.3d 361, 374 n.7 (3d Cir. 2002)). Federal notice and pleading rules require the complaint to provide “the defendant fair notice of what the . . . claim is and the grounds upon which it rests.”

Phillips, 515 F.3d at 232 (alteration in original) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). To test the sufficiency of the complaint, the court conducts a three-step inquiry. Santiago v. Warminster Township, 629 F.3d 121, 130-31 (3d Cir. 2010). In the first step, “the court must ‘tak[e] note of the elements a plaintiff must plead to state a claim.’” Id. at 130 (alteration in original) (quoting Ashcroft v. Iqbal, 556 U.S. 662, 675 (2009)). Next, the factual and legal elements of a claim must be separated; well-pleaded facts are accepted as true, while mere legal conclusions may be disregarded. Id. at 131-32; Fowler v. UPMC Shadyside, 578 F.3d 203, 210-11 (3d Cir. 2009). Once the court isolates the well-pleaded factual allegations, it must determine whether they are sufficient to show a “plausible claim for relief.” Iqbal,

556 U.S. at 679 (citing Twombly, 550 U.S. at 556). A claim is facially plausible when the plaintiff pleads facts “that allow[] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. Courts must liberally construe complaints brought by pro se litigants. Sause v. Bauer, 585 U.S. 957, 960 (2018). Pro se complaints, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007).

III. Discussion Reid’s federal constitutional claims are filed pursuant to 42 U.S.C. § 1983. Section 1983 creates a cause of action to redress constitutional wrongs committed by state officials. 42 U.S.C. § 1983. The statute is not a source of substantive rights, but serves as a mechanism for vindicating rights otherwise protected by federal law. See Gonzaga Univ. v. Doe, 536 U.S. 273, 284-85 (2002); Kneipp v. Tedder, 95 F.3d

1199, 1204 (3d Cir. 1996). To state a Section 1983 claim, plaintiffs must show a deprivation of a “right secured by the Constitution and the laws of the United States . . . by a person acting under color of state law.” Kneipp, 95 F.3d at 1204 (quoting Mark v. Borough of Hatboro, 51 F.3d 1137, 1141 (3d Cir. 1995)). At the outset, the claims against defendant lawyers Littman and Kivisto will be dismissed sua sponte. As the court explained in its order to show cause: [I]t appear[s] to the court that dismissal of the claims against defendants Littman and Kivisto for failure to state a claim is appropriate because a plaintiff seeking to assert civil rights claims pursuant to Section 1983 must allege that defendants acted under color of state law, see West v. Atkins, 487 U.S. 42, 48 (1988), and “[a]ttorneys performing their traditional functions will not be considered state actors solely on the basis of their position as officers of the court,” Angelico v. Lehigh Valley Hosp., Inc., 184 F.3d 268, 277 (3d Cir. 1999) (citing Polk County v. Dodson, 454 U.S. 312, 318 (1981)), and the court observing that an attorney’s actions are not deemed state action merely because the attorney is, like defendant Kivisto, paid out of the state fisc to represent a state employee, cf. Limehouse v. Delaware, 144 F. App’x 921, 923 (3d Cir. 2005) (“a private attorney, even if appointed and paid for by the state, is not acting under color of state law when performing his function as counsel” (citing Polk, 454 U.S. at 325); accord N’Jai v. Floyd, 386 F. App’x 141, 144 (3d Cir. 2010); Aruanno v. Blodgett, 339 F. App’x 258, 260 (3d Cir. 2009); Brown v. Terrell, 322 F. App’x 93, 94 (3d Cir. 2009); Gonzalez v. Feiner, 130 F. App’x 590, 592 n.2 (3d Cir.

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Related

Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Gonzaga University v. Doe
536 U.S. 273 (Supreme Court, 2002)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jacquelyn N'Jai v. Manuel Zuniga, Jr.
386 F. App'x 141 (Third Circuit, 2010)
Santiago v. Warminster Township
629 F.3d 121 (Third Circuit, 2010)
Kneipp v. Tedder
95 F.3d 1199 (Third Circuit, 1996)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Fowler v. UPMC SHADYSIDE
578 F.3d 203 (Third Circuit, 2009)
Mark v. Borough of Hatboro
51 F.3d 1137 (Third Circuit, 1995)
Limehouse v. State of DE
144 F. App'x 921 (Third Circuit, 2005)
Gonzalez v. Feiner
130 F. App'x 590 (Third Circuit, 2005)
Lafayette Brown v. David Martin, Jr.
322 F. App'x 93 (Third Circuit, 2009)
Sause v. Bauer
585 U.S. 957 (Supreme Court, 2018)
Aruanno v. Blodgett
339 F. App'x 258 (Third Circuit, 2009)

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Reid v. Munley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reid-v-munley-pamd-2025.