SAUNDERS v. FREEMAN

CourtDistrict Court, E.D. Pennsylvania
DecidedSeptember 26, 2025
Docket2:25-cv-05219
StatusUnknown

This text of SAUNDERS v. FREEMAN (SAUNDERS v. FREEMAN) 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
SAUNDERS v. FREEMAN, (E.D. Pa. 2025).

Opinion

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

ROBERT E. SAUNDERS, : Plaintiff, : : v. : CIVIL ACTION NO. 25-5219 : RILEY FREEMAN, et al., : Defendants. :

MEMORANDUM PADOVA, J. SEPTEMBER 25, 2025 Plaintiff Robert E. Saunders filed this pro se civil action against Defendants Riley Freeman and John Gaeta, Jr., asserting constitutional and state law claims based on an alleged tenancy agreement. Saunders also moves for leave to proceed in forma pauperis. For the following reasons, the Court will grant the request to proceed in forma pauperis and will dismiss the Complaint. I. FACTUAL ALLEGATIONS1 Saunders’s allegations are extremely brief. Saunders asserts that Defendant Riley Freeman “failed to protect” him by not providing a written lease agreement for the property that Saunders has been renting since January 2019.2 (See ECF No. 2 (“Compl.”) at 4.) Because of this failure, Saunders contends that the “owner/operator” (id. at 2), Defendant John Gaeta, Jr., has threatened and continued to harass Saunders to “get [Saunders] out of this property.” (Id. at 4.) Saunders claims that Freeman’s threats to move him “without a written lease agreement after

1 The facts set forth in this Memorandum are taken from the Complaint (ECF No. 2). The Court adopts the pagination assigned to the Complaint by the CM/ECF docketing system. Spelling, punctuation, and capitalization errors are cleaned up where necessary.

2 Freeman is identified as both a “renter” and “landlord” in the Complaint. (Compl. at 2, 4.) a 3yr. period is illegal.” (Id.) He further asserts that Gaeta is “forcing and taunting” him to remove him from the property illegally. (Id.) As a result of these events, Saunders asserts a violation of his Fourteenth Amendment due process rights as well as state law claims. (Id. at 3.) He alleges that he has suffered mental and physical injuries. (Id. at 5.) He seeks monetary

compensation in the aggregate amount of $8,000,000. (Id.) II. STANDARD OF REVIEW The Court grants Saunders leave to proceed in forma pauperis. Accordingly, 28 U.S.C. § 1915(e)(2)(B)(ii) requires the Court to dismiss Saunders’s Complaint if it fails to state a claim. Whether a complaint fails to state a claim under § 1915(e)(2)(B)(ii) is governed by the same standard applicable to motions to dismiss under Federal Rule of Civil Procedure 12(b)(6), see Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999), which requires the Court to determine whether the complaint contains “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face,” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotation omitted). At this early stage of the litigation, the Court will accept the facts alleged in

the pro se complaint as true, draw all reasonable inferences in the plaintiff’s favor, and consider only whether the complaint, liberally construed, “contains facts sufficient to state a plausible . . . claim.” Shorter v. United States, 12 F.4th 366, 374 (3d Cir. 2021) (quotation omitted), abrogation on other grounds recognized by Fisher v. Hollingsworth, 115 F.4th 197 (3d Cir. 2024). Conclusory allegations do not suffice. Iqbal, 556 U.S. at 678. As Saunders is proceeding pro se, the Court construes his allegations liberally. Vogt v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021) (citing Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 244-45 (3d Cir. 2013)). The Court will “apply the relevant legal principle even when the complaint has failed to name it.” Id. (quoting Mala, 704 F.3d at 244). However, “pro se litigants still must allege sufficient facts in their complaints to support a claim.” Id. (quoting Mala, 704 F.3d at 245). An unrepresented litigant “cannot flout procedural rules — they must abide by the same rules that apply to all other litigants.” Id. (quoting Mala, 704 F.3d at 245); see also Doe v. Allegheny Cnty. Hous. Auth., No. 23-1105, 2024 WL 379959, at *3 (3d Cir. Feb. 1,

2024) (per curiam) (“While a court must liberally construe the allegations and ‘apply the applicable law, irrespective of whether the pro se litigant mentioned it [by] name,’ Higgins v. Beyer, 293 F.3d 683, 688 (3d Cir. 2002), this does not require the court to act as an advocate to identify any possible claim that the facts alleged could potentially support.”). Finally, when allowing a plaintiff to proceed in forma pauperis, the Court must review the pleadings and dismiss the matter if it determines, inter alia, that the action fails to set forth a proper basis for this Court’s subject matter jurisdiction. Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”); Grp. Against Smog & Pollution, Inc. v. Shenango, Inc., 810 F.3d 116, 122 n.6 (3d Cir. 2016) (explaining that “an objection to subject matter jurisdiction may be raised at any time

[and] a court may raise jurisdictional issues sua sponte” (citations omitted)). A plaintiff commencing an action in federal court bears the burden of establishing federal jurisdiction. See Lincoln Ben. Life Co. v. AEI Life, LLC, 800 F.3d 99, 105 (3d Cir. 2015) (“The burden of establishing federal jurisdiction rests with the party asserting its existence.” (citing DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 n.3 (2006))). III. DISCUSSION Saunders asserts claims for constitutional violations pursuant to 42 U.S.C. § 1983. (See Compl. at 3.) “To state a claim under § 1983, a plaintiff must allege the violation of a right secured by the Constitution and laws of the United States, and must show that the alleged deprivation was committed by a person acting under color of state law.” West v. Atkins, 487 U.S. 42, 48 (1988) (citations omitted). “The color of state law element is a threshold issue; there is no liability under § 1983 for those not acting under color of law.” Groman v. Twp. of Manalapan, 47 F.3d 628, 638 (3d Cir. 1995) (citation omitted).

Saunders’s constitutional claims fail because none of the Defendants are alleged to be state actors. Whether a private entity is acting under color of state law – i.e., whether the defendant is a state actor subject to liability under § 1983 – depends on whether there is “such a close nexus between the State and the challenged action that seemingly private behavior may be fairly treated as that of the State itself.” Leshko v. Servis, 423 F.3d 337, 339 (3d Cir. 2005) (internal quotations omitted).

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Bluebook (online)
SAUNDERS v. FREEMAN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/saunders-v-freeman-paed-2025.