Case Law Young v. Sunbury Police Dep't

Young v. Sunbury Police Dep't

Document Cited Authorities (34) Cited in (9) Related

Joshua J. Cochran, Schemery Zicollello, Williamsport, PA, for Plaintiff.

Frank J. Lavery, Jr., Sunshine J. Thomas, Lavery Faherty, Harrisburg, PA, for Defendants.

MEMORANDUM

Matthew W. Brann, United States District Judge

Pending before this Court is a motion to dismiss for failure to state a claim upon which relief can be granted, pursuant to Federal Rule of Civil Procedure 12(b)(6), filed by Defendants Sunbury Police Department, Gary Heckman, and Christopher Blaise (hereinafter Defendants) against Plaintiff Matthew Young (hereinafter Mr. Young).1 The motion seeks to dismiss Mr. Young's claims for violations of the Americans with Disabilities Act, 42 U.S.C. § 12101 et. seq. , (hereinafter “ADA”) and the Rehabilitation Act, 29 U.S.C. § 794 (hereinafter “RA”) and for violations of the Fourteenth and Eighth Amendments under 42 U.S.C. § 1983.2 This matter has been fully briefed and is now ripe for disposition. In accordance with the following reasoning, Defendants' motion to dismiss is denied.

I. BACKGROUND

According to Mr. Young's complaint, he suffers from the following physical and mental disabilities : antrioventricular septal defect, mitral valve insufficiency, postural orthostatic tachycardia syndrome, seizures, neurocardiogenic syncope and palpitations, mild mental retardation, Asperger's syndrome, ADHD, developmental delay, speech delay, short stature disorder, growth hormone deficiency, facial dysmorphism, hearing loss, and failure to thrive.3 Due to his many disabilities, Mr. Young, age eighteen, speaks, understands, performs math, and reads at a third grade level for which he receives private tutoring. This tutoring was to have occurred at the Degenstein Community Library, Sunbury, Pennsylvania. Prior to the onset of the tutoring, Mr. Young and his father met with the library staff. Mr. Young's father explained the nature of Mr. Young's disabilities and asked them to call him if they experienced any issues with Mr. Young.

With that background in mind, on October 30, 2014, Mr. Young, then age seventeen, experienced a “serious health emergency in the form of an episode of a neurocardiogenic syncope /tonic-clonic seizure” while he was at the Degenstein Community Library waiting to begin a tutoring session.4 During the seizure, Mr. Young fell to the floor and began moving in an unusual fashion, which included tugging at his loose-fitting clothing. A library staff member observed this behavior but reported to the library director that she had witnessed Mr. Young lying on the floor, exposing himself, and masturbating. The library director proceeded to call 911 and reported the staff member's observations.

Police officers from the Sunbury Police Department were dispatched and Officer Gary Heckman arrived on the scene, followed minutes later by Officer Christopher Blaise. The officers proceeded to arrest Mr. Young. As Mr. Young was escorted through the library parking lot, Officer Blaise, who knew Mr. Young and his father, shouted to Mr. Young's father, who was then returning to the library, that Mr. Young had been “masturbating” and that he was being taken to the police station.

At the police station, the police proceeded to interrogate Mr. Young, refusing to allow Mr. Young to see his father and denying his father's request to obtain medical care for his son. After Mr. Young's father spoke to Officer Heckman and informed him of Mr. Young's disability and need for medical care, Officer Heckman replied, “I don't buy it. He knows what he's doing.”5 Mr. Young was eventually released into his father's custody and transported to a hospital where he was admitted for two days of treatment to stabilize him after the seizure. Mr. Young's arrest led to charges that were subsequently dismissed as baseless.

II. LEGAL STANDARD

Under Federal Rule of Civil Procedure 12(b)(6), a defendant may file a motion to dismiss for “failure to state a claim upon which relief can be granted.” Such a motion “tests the legal sufficiency of a pleading” and “streamlines litigation by dispensing with needless discovery and factfinding.”6 Rule 12(b)(6) authorizes a court to dismiss a claim on the basis of a dispositive issue of law.”7 This is true of any claim, “without regard to whether it is based on an outlandish legal theory or on a close but ultimately unavailing one.”8

Beginning in 2007, the Supreme Court of the United States initiated what some scholars have termed the Roberts Court's “civil procedure revival” by significantly tightening the standard that district courts must apply to 12(b)(6) motions.9 In two landmark decisions, Bell Atlantic Corporation v. Twombly and Ashcroft v. Iqbal, the Roberts Court “changed... the pleading landscape” by “signal[ing] to lower-court judges that the stricter approach some had been taking was appropriate under the Federal Rules.”10 More specifically, the Court in these two decisions “retired” the lenient “no-set-of-facts test” set forth in Conley v. Gibson and replaced it with a more exacting “plausibility” standard.11

Accordingly, after Twombly and Iqbal, “[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.”'12A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”13 “Although the plausibility standard does not impose a probability requirement, it does require a pleading to show more than a sheer possibility that a defendant has acted unlawfully.”14 Moreover, [a]sking for plausible grounds...calls for enough facts to raise a reasonable expectation that discovery will reveal evidence of [wrongdoing].”15

The plausibility determination is “a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.”16 No matter the context, however, [w]here a complaint pleads facts that are 'merely consistent with' a defendant's liability, it 'stops short of the line between possibility and plausibility of entitlement to relief.”'17

When disposing of a motion to dismiss, a court must “accept as true all factual allegations in the complaint and draw all inferences from the facts alleged in the light most favorable to [the plaintiff].”18 However, “the tenet that a court must accept as true all of the allegations contained in the complaint is inapplicable to legal conclusions.”19 “After Iqbal, it is clear that conclusory or 'bare-bones' allegations will no longer survive a motion to dismiss.”20 “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.”21

As a matter of procedure, the United States Court of Appeals for the Third Circuit has instructed that:

Under the pleading regime established by Twombly and Iqbal, a court reviewing the sufficiency of a complaint must take three steps. First, it must tak[e] note of the elements [the] plaintiff must plead to state a claim. Second, it should identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth. Finally, [w]hen there are well-pleaded factual allegations, [the] court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.22
III. DISCUSSION

Mr. Young's complaint consists of a claim against the Sunbury Police Department for violations of the ADA and RA (Count I) and a claim against Officers Gary Heckman and Christopher Blaise for violations of the Fourteenth and Eighth Amendments for a denial of medical care under 42 U.S.C. § 1983 (Count III).23 In their motion to dismiss, Defendants seek to dismiss both counts of Mr. Young's complaint. The Court will address these issues in turn.

A. Count I

Defendants request that the Court dismiss Count I of Mr. Young's complaint because Mr. Young failed to demonstrate a prima facie claim for a violation of the ADA and the RA. Specifically, Defendants' submit that the ADA and the RA are inapplicable to this case because the Third Circuit has never held that either the ADA or the RA apply to arrest cases. In the absence of Circuit precedent, they cite decisions from the United States Courts of Appeals for the Fifth and Eighth Circuits for the proposition that this Court should not use the ADA or the RA to circumscribe an officer's ability to arrest Plaintiff because of an alleged mental disability.”24 Mr. Young, conversely, argues that he has adequately pled facts to demonstrate a prima facie claim under the ADA and RA and cites cases from both this Court and the United States District Court for the Eastern District of Pennsylvania holding that the ADA and RA apply to arrest cases under the “wrongful arrest” and the “reasonable accommodations” theories.

Defendants also argue that Mr. Young has failed to satisfy the requirements of Ashcroft v. Iqbal25 because he failed to plead any facts 1) which tend to demonstrate that he was discriminated against or arrested because of his disability, 2) establishing that the Sunbury Police Department had a record of, or that Officers Heckman and Blaise had prior knowledge of, Mr. Young's disabilities, or 3) which suggest that the Sunbury Police Department receives federal financial assistance.26 Defendants also argue that Mr. Young's request for compensatory damages under the ADA and RA must be dismissed because compensatory damages are unavailable absent a showing of intentional discrimination and Mr. Young fails to plead any facts to support a finding of intentional discrimination.

In response, Mr. Young argues that he has pled sufficient facts to establish that the officers had knowledge of Mr. Young's disability and need for medical...

5 cases
Document | U.S. District Court — Middle District of Pennsylvania – 2017
Zavec v. Collins
"...or arrest, causing the person to suffer greater injury or indignity in that process than other arrestees."Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802, 810 (M.D. Pa. 2016) (internal footnotes omitted). Both parties concede that the ADA applies to arrests. Indeed, most courts to consid..."
Document | U.S. District Court — Middle District of Pennsylvania – 2016
Moffitt v. Tunkhannock Area Sch. Dist.
"... ... In City of Scranton , police officers brought civil rights actions alleging that the city violated ... 57 (1937). Pennsylvania case law provides little guidance. See Young v. Bethlehem Area Vo–Tech Sch., No. 06–cv–2285, 2007 WL 674617, at ... "
Document | U.S. District Court — Middle District of Pennsylvania – 2020
Young v. Scott Twp.
"...it was a reasonable response, if not the only reasonable response, to the situation"); compare with Young v. Sunbury Police Dep't , 160 F. Supp. 3d 802, 811 (M.D. Pa. 2016) (officer was told that plaintiff suffered from disabilities and required immediate medical attention but said he did n..."
Document | U.S. District Court — Middle District of Pennsylvania – 2021
Dunn v. Tunkhannock Twp.
"...previously held that compensatory damages are available in the arrest context under the ADA and the RA. See Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802, 810 (M.D. Pa. 2016). This court has also previously noted that "there are two theoriesunder which police actions have been found to..."
Document | U.S. District Court — Eastern District of Pennsylvania – 2020
Pukanecz v. Barta Transit Auth., 5:20-cv-00561
"...has alerted the public entity to his need for accommodation or the need for accommodation is obvious. See Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802, 810-11 (M.D. Pa. 2016). Under the second requirement, a plaintiff must show that the defendant deliberately failed to satisfy its dut..."

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1 books and journal articles
Document | Vol. 73 Núm. 6, June 2021 – 2021
Policing Under Disability Law.
"...93-112, 87 Stat. 355 (codified as amended at 29 U.S.C.[section][section] 701-796/). (128.) See, e.g., Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802,805 (M.D. Pa. (129.) The Rehabilitation Act provides that: No otherwise qualified individual with a disability ... shall, solely by reason..."

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1 books and journal articles
Document | Vol. 73 Núm. 6, June 2021 – 2021
Policing Under Disability Law.
"...93-112, 87 Stat. 355 (codified as amended at 29 U.S.C.[section][section] 701-796/). (128.) See, e.g., Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802,805 (M.D. Pa. (129.) The Rehabilitation Act provides that: No otherwise qualified individual with a disability ... shall, solely by reason..."

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  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

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5 cases
Document | U.S. District Court — Middle District of Pennsylvania – 2017
Zavec v. Collins
"...or arrest, causing the person to suffer greater injury or indignity in that process than other arrestees."Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802, 810 (M.D. Pa. 2016) (internal footnotes omitted). Both parties concede that the ADA applies to arrests. Indeed, most courts to consid..."
Document | U.S. District Court — Middle District of Pennsylvania – 2016
Moffitt v. Tunkhannock Area Sch. Dist.
"... ... In City of Scranton , police officers brought civil rights actions alleging that the city violated ... 57 (1937). Pennsylvania case law provides little guidance. See Young v. Bethlehem Area Vo–Tech Sch., No. 06–cv–2285, 2007 WL 674617, at ... "
Document | U.S. District Court — Middle District of Pennsylvania – 2020
Young v. Scott Twp.
"...it was a reasonable response, if not the only reasonable response, to the situation"); compare with Young v. Sunbury Police Dep't , 160 F. Supp. 3d 802, 811 (M.D. Pa. 2016) (officer was told that plaintiff suffered from disabilities and required immediate medical attention but said he did n..."
Document | U.S. District Court — Middle District of Pennsylvania – 2021
Dunn v. Tunkhannock Twp.
"...previously held that compensatory damages are available in the arrest context under the ADA and the RA. See Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802, 810 (M.D. Pa. 2016). This court has also previously noted that "there are two theoriesunder which police actions have been found to..."
Document | U.S. District Court — Eastern District of Pennsylvania – 2020
Pukanecz v. Barta Transit Auth., 5:20-cv-00561
"...has alerted the public entity to his need for accommodation or the need for accommodation is obvious. See Young v. Sunbury Police Dep't, 160 F. Supp. 3d 802, 810-11 (M.D. Pa. 2016). Under the second requirement, a plaintiff must show that the defendant deliberately failed to satisfy its dut..."

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  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

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  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

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