Rance Strunk, Sr. v. East Coventry Township Police, 674 F. App'x 221

In 2011 police received computer discs containing child pornography that had been left in a residence formerly used by Clifford Repotski.
Based in part on those discs, police obtained an arrest warrant; Repotski was arrested at a home shared with relatives and later pleaded guilty to most charges.
Repotski, two grandparents (the Strunks), his mother Yoder, and his minor brother R.A.Y. sued under 42 U.S.C. § 1983 alleging constitutional violations related to the arrest and search, naming multiple officers, the Chester County Detectives Division, and East Coventry Township.
The District Court dismissed the original and amended complaints for multiple reasons: Heck barred some claims, certain officers lacked personal involvement, municipal entities were improper or lacked a policy showing, and pleading failures under Rule 8.
The Third Circuit reviewed de novo, affirming dismissal overall but modifying the dismissal of malicious prosecution to be without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether malicious prosecution claim is barred by Heck	Malicious prosecution available despite conviction	Heck bars claims that would imply invalidity of conviction	Heck bars malicious prosecution; dismissal without prejudice (plaintiffs may refile if conviction invalidated)
Whether false arrest/false imprisonment claims survive despite warrant	Arrest unlawfully supported; warrant based on false/omitted facts	Arrest pursuant to warrant supported by affidavit; plaintiffs failed to plead deliberate falsehoods or material omissions	Claims dismissed: not barred by Heck but plaintiffs failed to plausibly allege officers knowingly/recklessly made false statements or omissions that defeated probable cause
Whether Officers Greenwalt and Jason are liable for illegal search	All named officers participated in or are responsible for the search	These officers did not actively participate in the search executed by other officers	Claims against Greenwalt and Jason dismissed for lack of personal involvement
Whether municipal/departmental liability or other statutory claims state a claim	County detectives unit, township, and various statutory causes of action are proper bases for relief	Chester County Detectives Division not a suable entity; no Monell policy/custom pleaded; statutory claims inadequately pleaded	Dismissed: detectives division improper party; no Monell policy alleged; other statutory/private causes of action insufficiently pleaded

Heck v. Humphrey, 512 U.S. 477 (establishing bar where success would imply invalidity of conviction)
Wilkinson v. Dotson, 544 U.S. 74 (clarifying scope of Heck-related relief and habeas distinction)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausible claims)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standard requiring plausibility)
Monell v. Dep’t of Soc. Serv., 436 U.S. 658 (municipal liability requires policy or custom)
Wilson v. Russo, 212 F.3d 781 (standards for false arrest claims based on warrant; deliberate falsehoods/omissions)
Groman v. Twp. of Manalapan, 47 F.3d 628 (false imprisonment requires absence of probable cause)
Mayer v. Belichick, 605 F.3d 223 (courts may consider exhibits attached to complaint on Rule 12(b)(6))
Rode v. Dellarciprete, 845 F.2d 1195 (§ 1983 liability requires personal involvement)