HomeMy WebLinkAbout02-209 CIVILRANDY DRAWBAUGH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 02-209 CIVIL
CIVIL ACTION - LAW
HAMPDEN TOWNSHIP
POLICE, PATROLMAN JAMES
MCANDREW, and PATROLMAN
STEVEN SHISSLER,
Defendants
IN RE: PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT
BEFORE BAYLEY AND HESS, J.J.
OPINION AND ORDER
This action was commenced on January 23, 2002, with the filing of a praecipe for a writ
of summons. A complaint was filed in April of 2002. The pro se complaint lacks clarity and the
factual allegations can be gleaned only with careful reading.
It appears that, on or about October 20, 2000, the plaintiff, Randy Drawbaugh, was
arrested and incarcerated. At the time of his arrest, his vehicle, a 1990 Dodge Daytona, was
parked at 160 Cassell Drive in Mechanicsburg, Pennsylvania. On October 30, 2000, concerned
that his vehicle may be being used by other persons who were not authorized to drive it, the
defendant sent a letter to the Hampden Township Police Department. In the letter he reported
that his car had been stolen by Lisa Kennedy and Sean Arnold. He also complained that
"whoever searched my car that day should never of [sic] gave them [sic] keys to them." See
Exhibit A to plaintiff' s complaint. Also attached to the plaintiff' s complaint is Exhibit B. This
consists of an incident report which makes it clear that the Hampden Township Police were not
involved in the search of the plaintiff' s vehicle nor was it the Hampden Township Police
Department that had possession of his keys. Exhibit B of the plaintiff' s complaint also contains
02-209 CIVIL
a letter from Patrolman James McAndrew, a Hampden Township police officer and a defendant
in this case. This letter reiterated that the Hampden Township Police had not been involved in
the search of the plaintiff' s vehicle nor had they given the keys to the vehicle to anyone. The
letter also indicated that ownership of the vehicle had been traced to a Lynn B. Lowe of East
Berlin, Pennsylvania. Patrolman McAndrew also indicated that he had had little contact with
Lisa Kennedy and Sean Arnold. Exhibit (2 of the plaintiff' s complaint is an affidavit dated
November 3, 2000, in which the plaintiff indicates that he had not given Lisa Kennedy or Sean
Arnold permission to operate his vehicle and requests that they be arrested. Exhibit D of the
plaintiff' s complaint is another letter from Patrolman James McAndrew. This letter is dated
December 4, 2000, and indicates that Patrolman James McAndrew had interviewed Lisa
Kennedy. She claimed to have been given permission to use the vehicle though, at the time of
the writing of the letter, she did not know its location or who was using the vehicle. Officer
McAndrew indicated that he had entered the vehicle into the nationwide police computer system
as a stolen vehicle, that the vehicle was eventually located and had been towed to a service
center. The letter, further, instructed the defendant to contact the West Manchester Township
Police Department in order to retrieve his vehicle.
The plaintiff' s complaint does not allege that the Hampden Township Police Department,
at any time, possessed either his vehicle or his keys. The gravamen of his complaint is that the
Hampden Township Police Department failed to honor his request to file charges against Sean
Arnold and Lisa Kennedy. The complaint seeks compensatory and punitive damages.
Plaintiff' s theory of recovery in the present action rests upon the argument that the
defendants, by not arresting Kennedy and Arnold, failed to properly perform their police duties.
The United States Supreme Court has held on numerous occasions that a private individual lacks
2
02-209 CIVIL
the authority to contest a police officer's discretion in arresting a third party. Linda R. S. v.
Richard D., 410 U.S. 614, 619, 35 L.Ed.2 536, 541 (1973). "[I]n American jurisprudence at
least, a private citizen lacks a judicially cognizable interest in the prosecution or nonprosecution
of another." Id.
According to The Pennsylvania Political Subdivision Torts Claim Act (the "Act"), "no
local agency shall be liable for any damages on account of any injury, to a person or property,
caused by any act of the local agency, or an employee thereof or any other person." 42
Pa.C.S.A. Section 8541. Thus, this section generally precludes plaintiff's claims against the
Hampden Township Police Department. His only recourse against the police department, or the
individual officers involved, would be if their alleged negligent acts fell within one of the eight
exceptions to immunity enumerated in the Act. The only potentially applicable exceptions
pertain to vehicle liability, and care, custody or control of personal property. The first exception
states that the local agency or its employees may be liable for negligent acts involving the
"operation of any motor vehicle in the possession or control of the local agency..." 42
Pa.C.S.A. § 8542(b)(1). The second exception involves the "care, custody or control of
personal property of others in the possession or control of the local agency." 42
Pa.C.S.A. § 8542(b)(2).
In order to remain faithful to the expressed legislative intent of the Act, courts are
required to interpret the exceptions narrowly against injured plaintiffs. See Leone v.
Com. 780 A.2d 754 (Pa. Commw. Ct. 2001). In the present case, plaintiff's cause of
action is for defendants' failure to arrest Arnold and Kennedy, and defendants' overall
failure to perform their duties. Nowhere in the pleadings is there any claim that the
3
02-209 CIVIL
defendants had "possession or control" of the vehicle, or that they had participated in the
"operation" of the vehicle. See 42 Pa.C.S.A. § 8542 (b)(1). There is also no claim that
defendants had the requisite "care, custody or control" of plaintiff's personal property.
See 42 Pa.C.S.A. § 8542 (b)(2).
Defendants McAndrew and Shissler are also generally immune from plaintiff's
claim of negligence. "An employee of a local agency is liable for civil damages on
account of any injury to a person or property caused by acts of the employee which are
within the scope of his office or duties only to the same extent as his employing local
agency and subject to the limitations imposed by this chapter." 42 Pa.C.S.A. § 8545. If
the defendants' actions do not fall within one of the narrowly defined exceptions in §
8542, then the individual defendants receive official immunity, unless the alleged injury
was caused by an act which constitutes "a crime, actual fraud, actual malice or willful
misconduct." 42 Pa.C.S.A. § 8550. Plaintiff's only cause of action against defendants is
for negligence. Nowhere does plaintiff aver that defendants' acts constituted a "crime,
actual fraud, actual malice or willful misconduct." Id.
Due to the fact that plaintiff's cause of action against defendants is limited to
negligence, the plaintiff's attempt to recover punitive damages is also barred. It has been
established that none of the exceptions to governmental immunity apply in this case.
Moreover, the plaintiff has not alleged that the defendants' actions were "malicious,
wanton, reckless, willful or oppressive," which is required for the granting of punitive
damages. Feld v. Merriam, 485 A.2d 742, 748 (Pa. 1984).
4
02-209 CIVIL
ORDER
AND NOW, this day of October, 2002, for the reasons stated in the
opinion filed of even date herewith, the preliminary objections of the defendants to the
plaintiff' s complaint are SUSTAINED and the within complaint DISMISSED.
BY THE COURT,
Kevin A. Hess, J.
Randy Drawbaugh, Pro Se
Inmate #CF6052
SCI-Mahonoy
301 Morea Road
Frackville, PA 17932
Plaintiff
James D. Young, Esquire
For the Defendants
:rlm
RANDY DRAWBAUGH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 02-209 CIVIL
CIVIL ACTION - LAW
HAMPDEN TOWNSHIP
POLICE, PATROLMAN JAMES
MCANDREW, and PATROLMAN
STEVEN SHISSLER,
Defendants
IN RE: PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT
BEFORE BAYLEY AND HESS, J.J.
ORDER
AND NOW, this day of October, 2002, for the reasons stated in the
opinion filed of even date herewith, the preliminary objections of the defendants to the
plaintiff' s complaint are SUSTAINED and the within complaint DISMISSED.
BY THE COURT,
Kevin A. Hess, J.
Randy Drawbaugh, Pro Se
Inmate #CF6052
SCI-Mahonoy
301 Morea Road
Frackville, PA 17932
Plaintiff
James D. Young, Esquire
For the Defendants
:rlm