DOE v. SOMERSET COUNTY DISTRICT ATTORNEY'S OFFICE
3:23-cv-00218
W.D. Pa.May 19, 2025Background
- Jane Doe filed a Section 1983 civil rights suit against Somerset County and former District Attorney Jeffrey Thomas, alleging sexual assault and related misconduct.
- Thomas was convicted at a criminal trial for acts including strangulation, unlawful restraint, and indecent assault, and is serving 7 years imprisonment.
- The complaint alleges Somerset County is liable under Monell for failing to supervise or discipline Thomas, and for maintaining policies or customs resulting in constitutional harm.
- Somerset County moved to dismiss, arguing Thomas was not acting under color of law, the County could not lawfully discipline an elected DA, and there was no actionable municipal policy or custom.
- Plaintiff amended her complaint to add Fourth and Fourteenth Amendment claims and has agreed to drop punitive damages claims against Somerset County.
- The case is at the motion to dismiss stage; the Court considered only whether Doe’s complaint states a plausible claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Color of law – Thomas | Thomas acted under color of state law during alleged assault | Thomas acted privately, not under color of law | Complaint plausibly alleges color of law action; dismissal denied |
| Monell liability – County | County failed to supervise/discipline, showing policy/custom | County cannot remove DA, no actionable custom identified | Complaint sufficiently alleges potential Monell liability, to be tested in discovery |
| Availability of punitive damages | Sought punitive damages against both defendants | County argued punitive damages barred for municipalities | Plaintiff agreed to drop claim; not at issue on motion |
| Sufficiency of pleadings under Twombly/Iqbal | Complaint alleges facts raising plausible claim | Claims speculative and insufficient as pled | Allegations sufficient to survive 12(b)(6) motion |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (establishes plausibility pleading standard for complaints)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (requires adequately pled facts to survive motion to dismiss)
- Conley v. Gibson, 355 U.S. 41 (1957) (notice pleading requirement)
- Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir. 2009) (applying plausibility standard to civil complaints)
- Connelly v. Steel Valley Sch. Dist., 706 F.3d 209 (3d Cir. 2013) (three-step analysis for plausibility in complaints)