Susan Lloyd v. Pennsylvania State Board of Veterinary Medicine; Michelle Roberts, Vet Board Administrator; Ashley Keefer; and Paul Jarabeck

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 27, 2026
Docket5:25-cv-05171
StatusUnknown

This text of Susan Lloyd v. Pennsylvania State Board of Veterinary Medicine; Michelle Roberts, Vet Board Administrator; Ashley Keefer; and Paul Jarabeck (Susan Lloyd v. Pennsylvania State Board of Veterinary Medicine; Michelle Roberts, Vet Board Administrator; Ashley Keefer; and Paul Jarabeck) 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
Susan Lloyd v. Pennsylvania State Board of Veterinary Medicine; Michelle Roberts, Vet Board Administrator; Ashley Keefer; and Paul Jarabeck, (E.D. Pa. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA ____________________________________

SUSAN LLOYD, : Plaintiff, : : v. : No. 5:25-cv-5171 : PENNSYLVANIA STATE BOARD OF : VETERINARY MEDICINE; : MICHELLE ROBERTS, VET BOARD : ADMINISTRATOR; ASHLEY KEEFER; : and PAUL JARABECK; : Defendants. : _____________________________________

O P I N I O N Motion to Dismiss, ECF No. 16 - Granted

Joseph F. Leeson, Jr. March 27, 2026 United States District Judge

I. INTRODUCTION This case arises out of complaints Plaintiff Susan Lloyd made to the Pennsylvania State Board of Veterinary Medicine (“PSBVM”) about the deaths of her service dogs. Defendants, the PSBVM and its employees, allegedly interfered with Lloyd’s ability to speak at a public meeting about the complaints. Defendants have moved to dismiss all claims based on the immunity of the PSBVM and Lloyd’s failure to state a claim. For the reasons set forth below, Defendants’ Motion to Dismiss is granted. II. BACKGROUND A. Procedural History Lloyd initiated the above-captioned action on September 5, 2025, based on federal question jurisdiction against the following defendants: the PSBVM; Michelle Roberts, the Board Administrator of the PSBVM; Ashley Keefer, legal counsel for the PSBVM; and Paul Jarabeck, a prosecutor for the PSBVM. See Am. Compl. ¶¶ 2-5, ECF No. 13. Defendants filed a Motion to Dismiss on November 10, 2025, see ECF No. 10, which was dismissed as moot after Lloyd filed an Amended Complaint.

In her Amended Complaint naming the same Defendants, Lloyd asserts the following four causes of action: violations of (I) the Pennsylvania Sunshine Act, 65 Pa.C.S. §§ 701-716, see Am. Compl. ¶¶ 85-122, ECF No. 13; (II) the First Amendment right to free speech, see id. ¶¶ 123-177; (III) the Fourteenth Amendment right to equal protection- class of one, see id. ¶¶ 178- 205; and (IV) the Fourteenth Amendment right to due process, see id. ¶¶ 206-221.1 Lloyd seeks monetary relief and various forms of injunctive and declaratory relief. See id. at pp. 38-39. Defendants responded by filing a Motion to Dismiss pursuant to Federal Rules of Civil Procedure 12(b)(1)2 and 12(b)(6). See Mot., ECF No. 16. Lloyd filed a brief in opposition. See Opp., ECF No. 17. B. Factual Allegations The pertinent3 factual allegations in the Amended Complaint are as follows: Two

1 Counts two through four are brought pursuant to 42 U.S.C. § 1983. 2 Defendants’ “assertion of Eleventh Amendment immunity is properly considered ‘a motion to dismiss the complaint for lack of subject matter jurisdiction under [Federal Rule of Civil Procedure] 12(b)(1).’” See Shepherd v. Armitage, No. 25-6328-KSM, 2026 U.S. Dist. LEXIS 31915, at *4 (E.D. Pa. Feb. 17, 2026) (quoting Blanciak v. Allegheny Ludlum Corp., 77 F.3d 690, 693 n.2 (3d Cir. 1996)). 3 Lloyd’s Amended Complaint contains numerous allegations. All her allegations, even those not specifically mentioned herein, have been considered by the Court in deciding the Motion to Dismiss. However, Lloyd’s conclusory allegations, of which there are many, see, e.g. Am. Compl. ¶ 18 (alleging “Defendants want to continue to masquerade their fraud to the public that they in fact do not protect the public as stated on their website, but in fact protect vets who kill animals”), are not entitled to the presumption of truth, see Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (holding that “the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions”). individual veterinarians4 allegedly “killed” Lloyd’s service dogs. See, e.g. Am. Compl. ¶ 77. Lloyd filed complaints against them, but the PSBVM never investigated. See id. ¶ 155. Lloyd claims that Defendants violated her due process rights by not holding a hearing on her complaints before dismissing the same. See id. ¶ 207.

On August 28, 2025, Lloyd emailed the PSBVM stating “. . . I want to speak at every future board hearing starting on Sept 5 at 1030 am about vet medmal which occurs in PA including the death of both of my dogs domino and double stuff who were killed by a vet.” See id. ¶ 12. See also Emails, ECF No. 16-2.5 Roberts denied Lloyd’s request. See Am. Compl. ¶ 13. Roberts stated: Pursuant to the Pennsylvania Supreme Court decision in Lyness v. State Bd. of Medicine, 605 A.2d 1204 (Pa. 1992), the Board is prohibited from comingling prosecutorial and adjudicatory functions. Accordingly, your request for an appointment at a future Board meeting for the stated purpose must be denied, as it would constitute a violation of the Lyness mandate. If you wish to bring a complaint to the Board’s attention, you may do so through the formal complaint process, which is available at pals.pa.gov. In the navigation options on the left side of the page, you will find a link to “File a Complaint.” A complaint submitted through this process will be directed to the Prosecutorial Division for review.

Email dated Aug. 28, 2025, at 02:18:05 PM. Lloyd wrote back threatening Roberts with civil action. See Am. Compl. ¶ 14. Keefer sent Lloyd an email the next morning stating: “I would be happy to explain why your request will not be accommodated.” See id. ¶ 15. Lloyd responded by again threatening civil action. See Emails Sept. 4, 2025, at 8:02 AM. Keefer replied less than twenty minutes later, stating:

4 Because the two veterinarians are not parties to this action and given the prejudicial nature of Lloyd’s accusations against them, their names are not included herein. Also not included herein are Lloyd’s specific allegations of wrongdoing against them because they are not material to the claims in the above-captioned action. 5 See Pryor v. Ncaa, 288 F.3d 548, 560 (3d Cir. 2002) (holding that “documents whose contents are alleged in the complaint and whose authenticity no party questions, but which are not physically attached to the pleading, may be considered” in deciding a motion to dismiss). As explained and pursuant to the Pennsylvania Supreme Court decision in Lyness v. State Bd. of Medicine, 605 A.2d 1204 (Pa. 1992), the Board is prohibited from comingling prosecutorial and adjudicatory functions. Accordingly, your request for an appointment at a future Board meeting for the stated purpose of discussing a pending investigation must be denied, as it would constitute a violation of the Lyness mandate. If you wish to bring a new complaint to the Board’s attention, you may do so through the formal complaint process, which is available at pals.pa.gov. In the navigation options on the left side of the page, you will find a link to “File a Complaint.” A complaint submitted through this process will be directed to the Prosecutorial Division for review.

Email dated Sept. 4, 2025, at 8:19 AM. The next day, September 5, 2025, Lloyd attempted to speak at a public meeting of the PSBVM,6 but “when” she tried to criticize the PSBVM “they” muted her microphone. See Am. Compl. ¶¶ 20, 24, 188. She was “never disruptive” during the meeting. See id. ¶ 27. Lloyd alleges that the “meeting was open to any comment about any topic” and “asked for public comments.” See id. ¶ 24. Lloyd alleges that Defendants allowed other members of the public to speak about whatever they wished, while preventing her from doing the same, which she claims violated her equal protection rights. See id. ¶¶ 188, 200. Lloyd claims that Defendants’ conduct also violated the Sunshine Act, her First Amendment right to free speech, and her right to due process. See generally id. ¶¶ 85-177, 209.7

6 Lloyd alleges that Defendants have concealed the minutes from the September 5, 2025 meeting.

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Susan Lloyd v. Pennsylvania State Board of Veterinary Medicine; Michelle Roberts, Vet Board Administrator; Ashley Keefer; and Paul Jarabeck, Counsel Stack Legal Research, https://law.counselstack.com/opinion/susan-lloyd-v-pennsylvania-state-board-of-veterinary-medicine-michelle-paed-2026.