GRAY v. ENTITY, PHILADELPHIA PARKING AUTHORITY, 2:25-cv-00918

Antonio Gray, Jr. sued the Philadelphia Parking Authority (PPA), claiming constitutional violations after the PPA impounded his 2007 Ford Explorer without a prior hearing.
Gray asserted he was denied due process under the Fifth and Fourteenth Amendments because he received no hearing before the vehicle’s seizure and the PPA ignored his subsequent disputes and paperwork.
Gray sought significant financial relief, including $50,000 per day, discharge of debt, and refunds of all impoundment fees.
Gray filed his complaint pro se and sought to proceed in forma pauperis (waiving court fees for indigence).
The court granted Gray’s request to proceed in forma pauperis but reviewed the sufficiency of his complaint under 28 U.S.C. § 1915(e)(2)(B)(ii), which requires dismissal if the complaint fails to state a claim.
The court considered whether Gray’s allegations plausibly stated a claim for municipal liability or a constitutional due process violation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Due Process	PPA impounded vehicle without a hearing, violating due process rights.	Due process was provided by post-impoundment notice.	No due process violation; adequate remedy existed.
Municipal Liability	PPA’s actions reflect a municipal custom or policy causing constitutional harm.	No identified policy/custom linked to alleged conduct.	No policy/custom alleged; Monell claim dismissed.
Existence of Constitutional Violation	Vehicle impoundment and lack of response to paperwork violated Fourteenth Amendment rights.	Procedures in place provided notice and appeal rights.	No constitutional violation pled.
Relief Sought (Sovereign Citizen Theories)	Court should enforce private “fee schedule” and trust paperwork against the PPA.	Such claims are legal nullities; not legally cognizable.	Sovereign citizen theories rejected; no relief.

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (standard for plausibility of allegations in pleadings)
West v. Atkins, 487 U.S. 42 (1988) (§1983 claim elements)
Monell v. Dept. of Social Servs., 436 U.S. 658 (1978) (municipal liability under §1983 must be based on official policy or custom)
Hudson v. Palmer, 468 U.S. 517 (1984) (no due process violation if adequate post-deprivation remedy exists)
Gilbert v. Homar, 520 U.S. 924 (1997) (due process is flexible and context-dependent)
Los Angeles v. Heller, 475 U.S. 796 (1986) (no municipal liability without underlying constitutional violation)