MOORE v. LEHIGH COUNTY PRISON
5:24-cv-02900
| E.D. Pa. | Jul 22, 2024Background
- Lindell Moore filed a pro se civil rights suit against Lehigh County Prison and several associated officials, alleging constitutional violations related to his arrest and incarceration in May 2023 for an alleged violation of a Protection From Abuse (PFA) order.
- Moore claimed wrongful imprisonment after being arrested during a custody hearing, asserting that exculpatory evidence provided by his wife was ignored by prison staff.
- Previously, Moore brought substantially the same claims against most of the same defendants in case No. 23-1900 ("Moore I"), which was dismissed with prejudice for failure to state a plausible claim.
- In Moore I, the court found Moore had not shown a lack of probable cause for his arrest, nor personal involvement by the prison officials.
- Moore sought leave to proceed in forma pauperis in the new action. The court granted this, but screened the complaint under 28 U.S.C. § 1915(e)(2).
- The court dismissed this new complaint with prejudice, citing claim preclusion (res judicata), as the same claims involving the same parties and facts had already been adjudicated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Plaintiff stated a viable claim | Moore alleges wrongful arrest and ignored exculpatory evidence | Defendants argue issues were previously dismissed, and no new facts alleged | Moore's claims do not state a plausible claim for relief |
| Applicability of claim preclusion (res judicata) | Moore argues for new relief based on the same incident | Defendants assert all elements of claim preclusion are met | Claim preclusion bars the new action |
| Personal involvement of prison officials | Moore claims officials ignored evidence of innocence | Defendants deny involvement/support prior dismissal | No new facts alleged; no personal involvement shown |
| Whether amendment would be futile | Moore seeks damages and amendment | Defendants argue defects cannot be cured | Amendment would be futile; dismissal with prejudice |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets the standard for plausibility of a claim in federal court)
- Sheridan v. NGK Metals Corp., 609 F.3d 239 (3d Cir. 2010) (claim preclusion applies when underlying facts are essentially the same)
- Marmon Coal Co. v. Dir., Office Workers’ Compensation Programs, 726 F.3d 387 (3d Cir. 2013) (sets out elements required for claim preclusion)