Todd v. Disability Rights Pennsylvania

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 4, 2025
Docket1:25-cv-01337
StatusUnknown

This text of Todd v. Disability Rights Pennsylvania (Todd v. Disability Rights Pennsylvania) 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
Todd v. Disability Rights Pennsylvania, (M.D. Pa. 2025).

Opinion

FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

JASON TODD, : Civil No. 1:25-CV-1337 : Plaintiff, : : v. : : DISABILITY RIGHTS : PENNSYLVANIA, : et al., : (Magistrate Judge Carlson) : Defendants. :

MEMORANDUM OPINION

I. Statement of Facts and Procedural History

This case comes before us for a legally mandated screening review of the plaintiff’s complaint. (Doc. 1). The pro se plaintiff, Jason Todd, has recently filed a spate of lawsuits in this court, including the instant case.1 Todd’s current complaint is a cryptic and enigmatic document drafted in a stream of consciousness style which presumes some vast pre-existing knowledge on the reader’s behalf of other unrelated events. In this pleading, Todd sues a disability rights organization, Disability Rights Pennsylvania, (DRP), and the Pennsylvania Human Relations Commission, (PHRC),

1 Todd v. Derry Township, 1:25-cv-435; Todd v. Commonwealth, 1:25-cv-1336; Todd v. Disability Rights of Pennsylvania, 1:25-cv-1337. 1 organizations. The meager factual recital which follows in support of the complaint alleges that Todd submitted “sealed trauma and VA medical documentation (Doc. 283) to federal court” following some altercation at a VA facility in September of

2024. (Id., at 4). What this documentation may be, or what the nature of this altercation was, remains a mystery since nothing is included in the instant complaint which provides further content, context, or coherence to this pleading. Instead, we are left to try to ferret out the meaning and content of this averment, as well as the

meaning of its reference to a document which is not part of this case. Todd then states that he also provided otherwise unidentified “formal complaints, trauma filings and international oversight notice[s]” to the DRP and the PHRC between February and

July 2025, but they closed his complaints. (Id., at 5). On the basis of this barebones factual recital, Todd then alleges in a cursory manner that the defendants have violated the Americans with Disabilities Act, 42 U.S.C. §12203; the general civil rights statute, 42 U.S.C. §1983; the Protection and

Advocacy for Individuals with Mental Illness Act, (PAIMI) 42 U.S.C. §§10801- 10805; the Supremacy Clause, Due Process Clause, and Equal Protection Clauses of the United States Constitution; and engaged in negligent misrepresentation. (Id., at

6). Relying upon these enigmatic averments, Todd demands $20,000,000 in

2 their jobs; and the appointment of a “federal trauma monitor.” (Id.) Todd was granted leave to proceed in forma pauperis subject to a screening review of this complaint. Todd has also filed a pleading consenting to proceed before

a magistrate judge. (Doc. 9). Therefore, since no other party has been served, for screening purposes we have sufficient party consent to proceed. See Neals v. Norwood, 59 F.3d 530, 532 (5th Cir. 1995). Having conducted this legally mandated screening review, for the reasons set

forth below, the complaint will be dismissed. II. Discussion A. Screening of Pro Se Complaints–Standard of Review

This court has an ongoing statutory obligation to conduct a preliminary review of pro se complaints brought by plaintiffs given leave to proceed in forma pauperis. See 28 U.S.C. § 1915(e)(2)(B)(ii). Specifically, we are obliged to review the complaint to determine whether any claims are frivolous, malicious, or fail to state a

claim upon which relief may be granted. This statutory text mirrors the language of Rule 12(b)(6) of the Federal Rules of Civil Procedure, which provides that a complaint should be dismissed for “failure to state a claim upon which relief can be

granted.” Fed. R. Civ. P. 12(b)(6). With respect to this benchmark standard for the legal sufficiency of a 3 the evolving standards governing pleading practice in federal court, stating that: Standards of pleading have been in the forefront of jurisprudence in recent years. Beginning with the Supreme Court’s opinion in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), continuing with our opinion in Phillips [v. County of Allegheny, 515 F.3d 224, 230 (3d Cir. 2008)], and culminating recently with the Supreme Court’s decision in Ashcroft v. Iqbal, BU.S.B, 129 S. Ct. 1937 (2009), pleading standards have seemingly shifted from simple notice pleading to a more heightened form of pleading, requiring a plaintiff to plead more than the possibility of relief to survive a motion to dismiss.

Fowler v. UPMC Shadyside, 578 F.3d 203, 209-10 (3d Cir. 2009). In considering whether a complaint fails to state a claim upon which relief may be granted, the court must accept as true all allegations in the complaint and all reasonable inferences that can be drawn therefrom are to be construed in the light most favorable to the plaintiff. Jordan v. Fox, Rothschild, O’Brien & Frankel, Inc., 20 F.3d 1250, 1261 (3d Cir. 1994). However, a court “need not credit a complaint’s bald assertions or legal conclusions when deciding a motion to dismiss.” Morse v. Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997). Additionally, a court need not “assume that a . . . plaintiff can prove facts that the . . . plaintiff has not alleged.” Associated Gen. Contractors of Cal. v. California State Council of Carpenters, 459 U.S. 519, 526 (1983). As the Supreme Court held in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), in order to state a valid cause of action, a plaintiff must provide some factual grounds for relief which “requires more than 4 will not do.” Id., at 555. “Factual allegations must be enough to raise a right to relief above the speculative level.” Id. In keeping with the principles of Twombly, the Supreme Court has

underscored that a trial court must assess whether a complaint states facts upon which relief can be granted when ruling on a motion to dismiss. In Ashcroft v. Iqbal, 556 U.S. 662 (2009), the Supreme Court held that, when considering a motion to dismiss, a court should “begin by identifying pleadings that, because they are no more than

conclusions, are not entitled to the assumption of truth.” Id., at 679. According to the Supreme Court, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id., at 678. Rather, in conducting a

review of the adequacy of a complaint, the Supreme Court has advised trial courts that they must: [B]egin by identifying pleadings that because they are no more than conclusions are not entitled to the assumption of truth. While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations.

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