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O'Neal v. Bedford County

United States District Court, W.D. Pennsylvania

January 19, 2017

CONSTANCE O'NEAL, Plaintiff,
v.
BEDFORD COUNTY and CATHY FETTER, acting in her official capacity as the BEDFORD COUNTY PROTHONOTARY/CLERK OF COURTS, Defendants.

          MEMORANDUM OPINION

          KIM R. GIBSON UNITED STATES DISTRICT JUDGE

         In this civil-rights case, plaintiff Constance O'Neal has sued Bedford County, Pennsylvania, and Bedford County's Prothonotary/Clerk of Courts, Cathy Fetter, in Fetter's official capacity. O'Neal alleges that defendants violated her constitutional rights by erroneously entering into the Bedford County court's docket system the terms of a criminal plea agreement O'Neal accepted in 2005. Pending before the Court is defendants' motion to dismiss (ECF No. 13). For the reasons that follow, defendants' motion to dismiss is GRANTED.

         I. Background

         The following facts are taken from plaintiff's complaint (ECF No. 1), which the court accepts as true for purposes of deciding the pending motion to dismiss. See N.J. Carpenters v. Tishman Constr. Corp., 760 F.3d 297, 302 (3d Cir. 2014) (citation omitted).

         On January 12, 2004 or 2005, [1] Constance O'Neal was arrested after a dispute with her ex- husband. (ECF No. 1 ¶ 13.) O'Neal was charged with theft and receiving stolen property, both graded as second-degree felonies, by the Bedford County District Attorney's Office. (See Id. ¶¶ 13-14.) The District Attorney's Office offered O'Neal a plea deal; if she pleaded guilty to the reduced offense of theft, graded as a first-degree misdemeanor, then the District Attorney's Office would not pursue all other charges. (Id. ¶ 14; ECF No. 1-2 at 2-3.) O'Neal accepted this offer and pleaded guilty to a first-degree misdemeanor charge of theft on April 25, 2005.[2] (ECF Nos. 1 ¶ 14-16; 1-2 at 2-3.)

         Although O'Neal's plea agreement and related documents clearly indicated that she had pleaded guilty to a first-degree misdemeanor charge, Bedford County's Prothonotary/Clerk of Courts, Cathy Fetter, erroneously entered the final disposition of O'Neal's case into the court's docket system as a guilty plea to a second-degree felony charge of theft.[3] (ECF Nos. 1 ¶ 2; 1-2 at 9, 12.) Relying on this entry, the Pennsylvania State Police likewise entered the erroneous felony conviction into its Central Repository. (ECF No. 1 ¶¶ 3, 23.) Both erroneous entries went undiscovered for approximately nine years. (See Id. ¶¶ 3-4.)

         In those nine years, as a result of the erroneous conviction data, O'Neal was denied scholarships as well as employment and other academic opportunities. (Id. ¶¶ 4, 26-34.) In February 2012, O'Neal was accepted as a student by the University of Pittsburgh-Johnstown. (Id. ¶ 28.) But after she completed paperwork for a criminal background check, O'Neal's admission was rescinded without explanation. (Id.) Similarly, O'Neal was accepted by St. Francis University in 2013 and offered a $24, 000 scholarship. (Id. ¶ 30.) But after she once again completed paperwork for a criminal background check, O'Neal's scholarship was rescinded and she withdrew from school. (Id. ¶ 31.) Furthermore, in March 2014 two prospective employers notified O'Neal that she was disqualified from working for them based on her criminal record. (Id. ¶¶ 32-33.) It appears that these notices by her prospective employers revealed the erroneous conviction data to O'Neal, who then took steps to have her record corrected; in March 2014, Fetter corrected the entry and informed the Pennsylvania State Police of the error. (Id. ¶ 25.)

         On March 4, 2016, O'Neal filed this case against Bedford County and Cathy Fetter in Fetter's official capacity as Bedford County's Prothonotary/Clerk of Courts. O'Neal brings this case under 42 U.S.C. § 1983, alleging that defendants violated her rights to meaningful educational and employment opportunities under the Fourteenth Amendment to the United States Constitution. O'Neal seeks compensatory damages.

         II. Jurisdiction & Venue

         Because O'Neal's claims arise under the Constitution and laws of the United States, this Court has jurisdiction pursuant to 28 U.S.C. § 1331. And because a substantial part of the events giving rise to O'Neal's claims-namely the erroneous recording of the disposition of O'Neal's 2005 criminal charges-occurred in the Western District of Pennsylvania, venue is proper in this district pursuant to 28 U.S.C. § 1391(b)(2).

         III. Legal Standards

         A. Motion to Dismiss

         Defendants have filed a motion to dismiss O'Neal's claims pursuant to Federal Rule of Civil Procedure 12(b)(6). The Federal Rules of Civil Procedure require that a complaint contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed.R.Civ.P. 8(a)(2). Rule 12(b)(6) allows a party to seek dismissal of a complaint for failure to state a claim upon which relief can be granted.

         The legal standard for a Rule 12(b)(6) motion is well established. In determining the sufficiency of a complaint, a district court must conduct a two-part analysis. First, the court should separate the factual and legal elements of the claims. Fowler v. UPMC Shadyside, 578 F.3d 203, 210 (3d Cir. 2009). Second, the court must determine whether the factual matters alleged are sufficient to establish that the plaintiff has a “plausible claim for relief.” Id. at 211 (quoting Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009)). The complaint, however, need not include “detailed factual allegations.” Phillips, 515 F.3d at 231 (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)).

         The court must also accept as true all factual allegations in the complaint and draw all inferences from the facts alleged in the light most favorable to the non-moving party. See Id. at 228 (citing Worldcom, Inc. v. Graphnet, Inc., 343 F.3d 651, 653 (3d Cir. 2003)). But “legal conclusions” and “[t]hreadbare recitals of the elements of a cause of action . . . do not suffice.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 555). Rather, the complaint must present sufficient “factual content that allows the court to draw the reasonable inference that the ...


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