Scicchitano v. Williams

CourtDistrict Court, M.D. Pennsylvania
DecidedOctober 2, 2025
Docket4:25-cv-00650
StatusUnknown

This text of Scicchitano v. Williams (Scicchitano v. Williams) 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
Scicchitano v. Williams, (M.D. Pa. 2025).

Opinion

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

CARMEN SCICCHITANO, No. 4:25-CV-00650

Plaintiff, (Chief Judge Brann) v.

JAMES WILLIAMS, SR., et al.,

Defendants.

MEMORANDUM OPINION

OCTOBER 2, 2025 I. BACKGROUND On April 11, 2025, Plaintiff, Carmen Scicchitano, (“Scicchitano”), filed a three-count complaint against Defendants, James Williams, Sr. (“Williams”), Former Officer David Donkochik (“Donkochik”), Police Chief Christopher Buhay (“Buhay”) Mount Carmel Borough (“Mount Carmel”), and Mount Carmel Police Officers John/Jane Doe 1–2 (“John/Jane Doe”).1 The counts of the complaint included a 42 U.S.C. § 1983 (“Section 1983”) claims for first amendment violations, a Section 1983 claim for manufacturing and fabricating evidence in violation of Mr. Scicchitano’s Fourteenth Amendment due process rights, and a state malicious prosecution claim.2 However, on June 24, 2025, all parties agreed to dismiss by stipulation the Section 1983 claim relating to first amendment violations.3

1 Doc. 1. 2 Id. On June 24, 2025, Williams filed a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The motion is now ripe for

disposition; for the reasons that follow, it is denied. II. DISCUSSION A. Motion to Dismiss Standard Under Federal Rule of Civil Procedure 12(b)(6), courts dismiss a complaint,

in whole or in part, if the plaintiff fails to “state a claim upon which relief can be granted.” Following the landmark decisions of Bell Atlantic Corp. v. Twombly4 and Ashcroft v. Iqbal,5 “[t]o survive a motion to dismiss, a complaint must contain

sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”6 The United States Court of Appeals for the Third Circuit has instructed that “[u]nder the pleading regime established by Twombly and Iqbal, a court reviewing the sufficiency of a complaint must take three steps”: (1) “take note of the

elements the plaintiff must plead to state a claim”; (2) “identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth”; and (3) “assume the[] veracity” of all “well-pleaded factual allegations” and

then “determine whether they plausibly give rise to an entitlement to relief.”7

4 550 U.S. 544 (2007). 5 556 U.S. 662 (2009). 6 Id. at 678 (quoting Twombly, 550 U.S. at 570). 7 Connelly v. Lane Construction Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal quotations and citations omitted). B. Facts Alleged in the Complaint The facts alleged in the complaint, which this Court must accept as true for

the purposes of this motion, are as follows. Carmen Scicchitano was a member of the Mount Carmel Fire Company, as was Defendant Williams—the then appointed President of the department.8 On April 22, 2018, Scicchitano was picking up his grandson from his home, which is near the

fire company’s headquarters.9 While on the street between the home and the fire headquarters, Scicchitano recorded members of the department who were near the garage doors in order to “gauge the siren levels.”10 In that recording, Williams could

be heard harassing and threatening Scicchitano’s son.11 After a consultation with an attorney,12 Scicchitano reported the conduct—and provided the recording—to the Governor’s Office of Homeland Security after it was requested.13 Several days later, Williams reported to officers Buhay and Donkochik that

Scicchitano had recorded him without his permission and sent the recording to the Governor’s Office.14 This led to the officers initiating and charging Scicchitano with felony wiretapping charges in state court.15 Scicchitano alleges that both Officers

8 Doc. 1 ¶¶ 7, 14. 9 Id. at ¶ 13. 10 Id. 11 Id. at ¶¶ 13, 15. 12 That same attorney had previously informed Williams in 2016, that Scicchitano “was constitutionally-permitted to photograph in public.” Id. at ¶ 15. 13 Id. at ¶ 15. 14 See id. at 16. 15 Id. at ¶¶ 15–16. Buhay and Donkochik were aware that the recording was a constitutionally protected activity under the First Amendment of the U.S. Constitution.16 He also says that

during the state proceedings the recording was edited to cut out parts that showed that the recording took place in public and was relating to a public official.17 Additionally, Williams claimed that the garage doors to the fire department were

closed at the time the recording took place—meaning he alleged that the recording was not made in public.18 Further, in November 2018, Officer Donkochik acknowledged that the state wiretapping charges were meritless, but told Scicchitano that he “did not give a fuck

and that the judge was in his pocket.”19 At this meeting Officer Donkochik also physically threatened Scicchitano.20 Officer Donkochik proved to be incorrect, as six years later, on December 2, 2024, all charges were dismissed against Scicchitano.21 However, that criminal case was the basis to remove Scicchitano as a

member of the fire department.22 Scicchitano alleges that practices like those

16 Id. at ¶ 17. 17 Id. at ¶ 19. 18 Id. 19 Id. at ¶ 21. 20 Id. It should be noted that in an unrelated matter regarding use of excessive force when arresting people as an officer, Donkochik pled guilty to conspiracy to deprive rights under color of law in violation of 18 U.S.C. § 241 before this Court. Press Release, U.S. Atty’s Off., M.D. Pa., Former Mt. Carmel Borough Police Officer Pleads Guilty to Conspiring to Violate Civil Rights (Mar. 14, 2025), available at https://www.justice.gov/usao-mdpa/pr/former-mt- carmel-borough-police-officer-pleads-guilty-conspiring-violate-civil-rights [https://perma.cc/GRV3-JZBH]. He was charged with two other officers from the Mt. Carmel Borough Police Department. Id. 21 Doc. 1 at ¶¶ 18–19. 22 Id. at 20. employed against him in his case were “a custom and de facto policy” in the station “of allowing criminal police officers to engage in malicious prosecutions with

manufactured evidence.”23 C. Analysis Scicchitano initiated the instant suit to recover compensatory and punitive damages for the alleged violation of his Fourteenth Amendment due process rights

and for state malicious prosecution. The former claim is accordingly brought under Section 1983. Defendant Williams’ Brief in Support of his Motion to Dismiss highlights three tenants of reasoning for why the complaint should be dismissed: (1)

Plaintiff’s failure to plead facts supporting the claim that Williams was acting under the color of law, (2) Plaintiff’s allegation that the charges were dismissed before trial causes his Fourteenth Amendment claim to fail, and (3) Plaintiff’s failure to plead facts supporting the claim that proceedings were initiated by Williams as required

for a state malicious prosecution claim.24 Additionally, Williams offers an exhibit— the affidavit of probable cause in the state proceedings against Scicchitano—to be considered along with his motion to dismiss.25 The Court begins by addressing

whether it will consider the exhibit and will then address each tenant of Williams’ brief.

23 Id. at ¶ 31. 24 Doc. 24. 25 Doc. 23. 1. Consideration of the Affidavit of Probable Cause When deciding a motion to dismiss, a court generally considers only the

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