Lewis v. Keuerleber
1:25-cv-00447
M.D. Penn.May 14, 2025Background
- Plaintiffs filed a 224-page complaint alleging various federal criminal and civil rights violations on March 11, 2025.
- At the same time, plaintiffs filed a motion for summary judgment before service on defendants, any responsive pleadings, or discovery.
- In the two months following, plaintiffs filed approximately fifteen motions in the case.
- Defendants had not yet been served and had not responded to the complaint as of this ruling.
- Both parties consented to magistrate judge jurisdiction; the summary judgment motion was fully briefed and ripe for decision.
- The court reviewed the timing and appropriateness of ruling on summary judgment at this early stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prematurity of Summary Judgment | No genuine factual disputes; entitled to judgment as a matter of law. | Defendants should have opportunity to respond and conduct discovery. | Motion is premature; denied without prejudice to renewal post-discovery. |
| Need for Discovery | Judgment appropriate now; record is sufficient. | Record not developed; no factual discovery has occurred. | Parties must have adequate opportunity for discovery before summary judgment. |
| Service of Process | Irrelevant to summary judgment motion. | Plaintiffs have not completed proper service. | Lack of service contributes to prematurity of motion. |
| Factual Development | Facts are clear and uncontested. | Dispute as to facts not yet addressed; no evidence presented. | No fully developed record; summary judgment unwarranted. |
Key Cases Cited
- Conoshenti v. Pub. Serv. Elec. & Gas Co., 364 F.3d 135 (3d Cir. 2004) (describes the burden of the moving party on summary judgment)
- A.W. v. Jersey City Pub. Schs., 486 F.3d 791 (3d Cir. 2007) (standard for reviewing summary judgment in favor of the non-movant)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (court must view facts in light most favorable to non-moving party on summary judgment)
- Big Apple BMW, Inc. v. BMW of North America, Inc., 974 F.2d 1358 (3d Cir. 1992) (summary judgment inappropriate where a factual dispute exists)