Ansman v. Cousins
3:21-cv-00040
| M.D. Penn. | Nov 15, 2021Background
- Plaintiff John J. Ansman, an inmate at SCI–Huntingdon, sued several Pennsylvania DOC employees (including CRNP Jessica Cousins, and officers Sisto, Gross, Ralston, John Wetzel, and Amanda West) under 42 U.S.C. § 1983.
- Complaint consists of a nine‑page narrative plus 41 pages of exhibits (inmate requests from 2017–2020) alleging various, disjointed claims across multiple years.
- Defendants filed two separate Rule 12(b)(6) motions to dismiss (Cousins and the remaining corrections defendants).
- Court reviewed pleading under Twombly/Iqbal and related Third Circuit precedent: factual allegations accepted, legal conclusions disregarded.
- Court determined the complaint violated Rules 8(d)(1) and 20(a)(2) because it was not simple/conise and improperly joined unrelated claims against multiple defendants; noted PLRA concerns about fee circumvention.
- Court granted the motions to dismiss but granted Ansman leave to file an amended complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of pleading under Twombly/Iqbal (Rule 12(b)(6)) | Ansman alleged constitutional claims via his narrative and attached inmate requests | Complaint is rambling and conclusory, lacking factual allegations showing entitlement to relief | Court applied Twombly/Iqbal, found allegations conclusory and unclear, supporting dismissal (with leave to amend) |
| Permissible joinder under Rule 20 and Rule 8 | Ansman joined multiple DOC employees in one action asserting various complaints | Claims arise from different transactions/timeframes and do not present common questions; joinder would circumvent PLRA filing fee rules | Court held joinder improper under Rule 20 and Rule 8; dismissal warranted, but plaintiff may amend to cure joinder/pleading defects |
| Remedy: dismissal vs. dismissal with prejudice | Ansman sought adjudication of claims in this suit | Defendants sought dismissal for pleading and joinder defects | Court dismissed complaint for procedural/pleading deficiencies but afforded leave to amend rather than entering final judgment |
Key Cases Cited
- Scheuer v. Rhodes, 416 U.S. 232 (1974) (motion to dismiss standard: whether plaintiff is entitled to offer evidence)
- Nami v. Fauver, 82 F.3d 63 (3d Cir. 1996) (pleading standard on dismissal)
- Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir. 2008) (accept factual allegations, draw reasonable inferences)
- Tellabs, Inc. v. Makor Issues & Rights, Ltd., 551 U.S. 308 (2007) (court may consider documents incorporated by reference and judicially noticeable matters)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions are not entitled to assumption of truth)
- Connelly v. Lane Const. Corp., 809 F.3d 780 (3d Cir. 2016) (application of Twombly/Iqbal in three-step framework)