Coppolino v. Commissioner Pennsylvania State Police
693 F. App'x 128
| 3rd Cir. | 2017Background
- Coppolino, a convicted sex offender, challenged Pennsylvania’s Megan’s Law IV in state court arguing it imposed ex post facto punishment and was unconstitutionally overbroad/vague.
- The named respondent in state court was Frank Noonan, Commissioner of the Pennsylvania State Police.
- The Pennsylvania Commonwealth Court rejected Coppolino’s ex post facto and due process/overbreadth claims; the Pennsylvania Supreme Court summarily affirmed.
- Two months after the state high court’s affirmance, Coppolino filed a § 1983 suit in federal district court against Noonan raising the same ex post facto and due process claims.
- The District Court dismissed the federal suit as barred by res judicata; it found the claims and parties identical and amendment would be futile.
- The Third Circuit affirmed, applying Pennsylvania preclusion law under the Full Faith and Credit statute and concluding claim preclusion barred relitigation in federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Coppolino's § 1983 suit is barred by res judicata | Coppolino argued his federal suit was not barred and sought to relitigate ex post facto and due process challenges to Megan’s Law IV | Noonan argued the state-court adjudication precludes relitigation of the same claims and parties in federal court | Court held res judicata bars the federal suit because the claims, parties, and capacities were the same and state courts already decided the issues |
| Whether Pennsylvania law requires dismissal under Full Faith and Credit analysis | Coppolino contended federal forum appropriate for § 1983 claims | Noonan argued federal courts must give state-court judgments preclusive effect per 28 U.S.C. § 1738 | Court applied Pennsylvania preclusion law and found preclusion appropriate |
| Whether substitution of current commissioner defeats preclusion | Coppolino suggested substitution matters because Noonan was replaced by Blocker | Noonan (defense) argued office substitution is pro forma and does not avoid preclusion under rules allowing substitution | Court held substitution is pro forma; suing the office is equivalent and preclusion still applies |
| Whether amendment to sue Noonan individually should have been allowed | Coppolino sought leave to amend to sue Noonan individually | Noonan argued amendment would be futile due to statute of limitations and lack of alleged personal involvement | Court held amendment would be futile: time-barred and no plausible personal-involvement allegations |
Key Cases Cited
- Labelle Processing Co. v. Swarrow, 72 F.3d 308 (3d Cir. 1995) (res judicata bars relitigation of same causes of action)
- Marrese v. Am. Acad. of Orthopaedic Surgeons, 470 U.S. 373 (U.S. 1985) (Full Faith and Credit requires federal courts to apply state preclusion law to state judgments)
- Lehman v. Lycoming Cty. Children’s Serv. Agency, 648 F.2d 132 (3d Cir. 1981) (federal constitutional claims litigated in state court may be precluded from federal relitigation)
- Coppolino v. Noonan, 102 A.3d 1254 (Pa. Commw. Ct. 2014) (state court decision rejecting Coppolino’s ex post facto and overbreadth/due process challenges)
- Coppolino v. Noonan, 125 A.3d 1196 (Pa. 2015) (Pennsylvania Supreme Court affirmance)
- Kach v. Hose, 589 F.3d 626 (3d Cir. 2009) (amendment futile where statute-of-limitations bars claim)
- Evancho v. Fisher, 423 F.3d 347 (3d Cir. 2005) (§ 1983 monetary liability requires allegations of personal involvement)