This case arose from a 2009 police encounter in which Pennsylvania state troopers responded to a call at the home of Levi Mohney, a mentally disabled man who had poured gasoline on himself; after he refused orders to come outside or lie down, one trooper deployed a taser, igniting the gasoline and causing fatal burns. Mohney’s estate sued the Commonwealth, state police, individual troopers, and supervisors under 42 U.S.C. § 1983 for alleged Fourth and Fourteenth Amendment violations stemming from excessive force and failure to accommodate his disability, as well as claims under the Americans with Disabilities Act and Rehabilitation Act. On a Rule 12(b)(6) motion to dismiss, the court examined whether the amended complaint adequately pled that the troopers knew of Mohney’s disability, that exigent circumstances were absent, and that the taser use violated clearly established law or ADA accommodation requirements, while applying the post-2009 “regarded as” definition of disability and noting the dismissal of ADA claims against individual officers.
The case involved a lawsuit by Kelly Schor against North Braddock Borough and its police officers after Officer Max Wittlinger shot and killed her escaped six-year-old pit bull dog in October 2010, despite the dog's lack of aggression and the owner's proximity and attempts to retrieve it. Schor asserted federal claims under 42 U.S.C. § 1983, including Fourth Amendment violations and failure to train, along with various Pennsylvania state-law claims such as negligence, conversion, and punitive damages. On the defendants' partial motion to dismiss, the court dismissed official-capacity claims, substantive due process claims, several state tort claims barred by governmental immunity under the Pennsylvania Political Subdivisions Tort Claims Act, and punitive damages against the borough, but denied dismissal of the Fourth Amendment seizure claim and the failure-to-train claim against the borough because the complaint sufficiently alleged plausible facts. The court reasoned that well-pleaded allegations must be accepted as true and that certain claims failed to meet Twombly/Iqbal plausibility standards or were precluded by immunity exceptions.
This case is a judicial review under 42 U.S.C. § 405(g) of the Social Security Administration's denial of disability insurance benefits to plaintiff Gianine Bracciodieta-Nelson, who alleged inability to work since 2006 due to panic attacks, anxiety, depression, chest pain, and related impairments. The ALJ found her conditions severe but not meeting listed criteria and determined she could perform a range of light work based on medical records, treatment history, and vocational expert testimony. The court granted summary judgment to the Commissioner and affirmed the denial. It reasoned that substantial evidence supported the ALJ's assessment of the plaintiff's impairments, limitations, and credibility.
This case arose from an insurance dispute in which plaintiff William Simmons sought coverage under a business policy for tools stolen from his Pennsylvania business in 2004; Nationwide investigated and denied the claim in 2005. Simmons sued for breach of contract, breach of the duty of good faith and fair dealing, and statutory bad faith under 42 Pa. C.S.A. § 8371. The court granted the insurer’s motion to dismiss in part by dismissing the good-faith-and-fair-dealing count, reasoning that Pennsylvania does not recognize an independent common-law claim for breach of that duty. It denied the motion to strike the fiduciary reference and the demand for compensatory damages in the statutory bad-faith count, concluding that the language was not redundant or improper under the statute.
The case involved Richard McDonald, a former police officer with a back injury and prescribed narcotic pain medication, who was denied recertification by the Municipal Police Officers Education and Training Commission (under the Pennsylvania State Police) to serve as a police chief despite medical reports supporting his fitness. McDonald sued the PSP and several officials, alleging due process violations in the denial of his application and related claims. The court granted summary judgment to the defendants, holding that the existing certification review process, including medical advisor input and notifications, satisfied due process requirements and that no additional hearing or procedure was mandated. Officials were also entitled to qualified immunity because no clearly established right to further process had been violated.
This case involves a breach of contract dispute between PPG Industries and Generon IGS over a five-year supply agreement for a specialty polymer product called TBBA, in which PPG alleged that Generon failed to meet purchase quotas and that an amendment released certain claims. Generon responded with counterclaims alleging breaches of the supply agreement by PPG, along with unjust enrichment and fraud in the inducement. The court denied PPG's motion to partially dismiss four of the counterclaims under Federal Rule of Civil Procedure 12(b)(6). In its reasoning, the court applied the plausibility standard from Twombly and Iqbal, accepted the counterclaim allegations as true, and determined that the fraud claim was not clearly barred by Pennsylvania's gist of the action doctrine at this early stage because it was unclear whether the alleged fraud related to contract inducement or performance.
