Opinion

Vincent Vince v. Matthew Godlewski

Court
Court of Appeals for the Third Circuit
Filed
Jun 3, 2026
Status
Unpublished
Cited by
0 cases
Authority
More cited than 40.8%

concluding that handcuffing can be unreasonable if it was done unnecessarily or excessively

How later courts described this case

  • concluding that handcuffing can be unreasonable if it was done unnecessarily or excessively

Written by the judges who cited it.

The opinion

U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 25-1756

VINCENT ANTHONY VINCE,

Appellant

v.

MATTHEW GODLEWSKI, in his individual capacity; JONATHAN KASKEY, in

his individual capacity; JOSEPH WOZNIAK, in his individual capacity; JOHN

CARLOS RODRIGUEZ, JR., in his individual capacity; ROBERT CAPPARELL,

in his individual capacity; JOHN DOE No.1, in his individual capacity; JOHN

DOE No. 2, in his individual capacity

_____________________________

Appeal from U.S. District Court, M.D. Pa.

Judge Julia K. Munley, No. 3:24-cv-00902

Before: RESTREPO, FREEMAN, and MASCOTT, Circuit Judges

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) January 21, 2026

Decided: June 3, 2026

_____________________________

NONPRECEDENTIAL OPINION*

RESTREPO, Circuit Judge.

Appellant Vincent Anthony Vince appeals the District Court’s order granting ap-

pellees’ motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure

to state a claim. For the following reasons, we will affirm the order.

*

This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding

precedent.

I. BACKGROUND

The appellees are five officers from the Wilkes-Barre Township Police Department.

Vince contends that those officers violated his Fourth, Fifth, and Fourteenth Amendment

rights under 42 U.S.C. § 1983 (“Section 1983”). The action arises from an incident on

June 3, 2022, when Vince was retrieving his car from ACT Towing in Wilkes-Barre Town-

ship, Luzerne County, Pennsylvania. The appellees approached Vince and informed him

they were arresting him based on an active warrant for an alleged violation of a Protection

from Abuse Order. He advised the officers that the warrant had been dismissed by a judge

of the Luzerne County Court of Common Pleas, but the appellees insisted that they had

verified the warrant.

Vince contacted his lawyer who advised the appellees that the warrant had been

lifted, and he could provide proof later that day. Vince’s counsel directed the appellees to

contact the Luzerne County Prothonotary’s Office or Vince’s wife to confirm the dismissal.

Vince contends that the appellees refused to confirm those details, and instead, they placed

him in handcuffs and advised him of his rights. He alleges that the appellees held him in

a “hot, unairconditioned vehicle” for 3–4 hours until his wife secured copies of the court

order nullifying the warrant. Id. After viewing the court order, the appellees made several

phone calls before releasing Vince from custody. The same lawyer involved in the under-

lying incident currently represents Vince in this action.

Vince claims that he suffered trauma and severe emotional distress as a result of the

incident. On June 6, 2024, he filed this lawsuit and alleged four causes of action: Count I

– Section 1983 claims for false arrest, excessive force, and due process violations; Count

2

II – false arrest; Count III – false imprisonment; and Count IV – intentional infliction of

emotional distress. In August 2024, the appellees moved pursuant to Federal Rule of Civil

Procedure 12(b)(6) to dismiss all counts for failure to state a claim.

On March 21, 2025, the District Court granted the appellees’ motion as to the Sec-

tion 1983 claims and determined that the officers were protected by qualified immunity

because they had “reasonably mistaken probable cause.” JA15. The District Court did not

give Vince leave to amend his complaint, finding that doing so would be futile. And fi-

nally, the District Court declined to exercise supplemental jurisdiction over the remaining

state law claims for false arrest, false imprisonment, and intentional infliction of emotional

distress, and dismissed those claims without prejudice. Vince appealed the District Court’s

dismissal of his complaint.

II. STANDARD OF REVIEW1

We exercise plenary review of a district court’s order granting a motion to dismiss

under Rule 12(b)(6), and we may affirm on any basis supported by the record. Stringer v.

Cnty. of Bucks, 141 F.4th 76, 84 (3d Cir. 2025). Because our review is de novo, we “accept

all factual allegations as true, construe the complaint in the light most favorable to the

plaintiff, and determine whether, under any reasonable reading of the complaint, the plain-

tiff may be entitled to relief.” Phillips v. Cnty. of Allegheny, 515 F.3d 224, 233 (3d Cir.

2008) (quoting Pinker v. Roche Holdings Ltd., 292 F.3d 361, 374 n.7 (3d Cir. 2002)).

1

The District Court had jurisdiction over the appellant’s Section 1983 claims pursuant to

28 U.S.C. § 1331 and supplemental jurisdiction over his state law claims pursuant to 28

U.S.C. § 1367(a). We have appellate jurisdiction under 28 U.S.C. § 1291.

3

III. SECTION 1983

Section 1983 does not create substantive rights, rather, it provides remedies for dep-

rivations of rights established in the Constitution or under federal law. Kneipp v. Tedder,

95 F.3d 1199, 1204 (3d Cir. 1996). Under Section 1983, a plaintiff must establish a viola-

tion of a constitutional right caused by a person acting under the color of state law. Phillips,

515 F.3d at 235. There is no question that the appellees were acting under the color of the

law, and thus, we are left to “identify the exact contours of the underlying right said to have

been violated.” Cnty. of Sacramento v. Lewis, 523 U.S. 833, 841 n.5 (1998). Here, Vince

alleges that his Fourth, Fifth, and Fourteenth Amendment rights were violated.

A. THE FIFTH AND FOURTEENTH AMENDMENTS

The District Court dismissed Vince’s Fifth Amendment claim because the Fifth

Amendment only restricts the actions of federal officials, and the appellees, who are mu-

nicipal officers, are not federal officials. JA8–9 (citing Nguyen v. U.S. Cath. Conf., 719

F.2d 52, 54–55 (3d Cir. 1983)). We agree, and the District Court therefore committed no

error in dismissing the Fifth Amendment claim.

Vince also challenges the District Court’s dismissal of his Fourteenth Amendment

claim, arguing that he “clearly pleaded” that the appellees “acted under color of state law

[and] violated [his] Fourteenth Amendment right to procedural and substantive due process

of law.” Appellant Br. 26. But Vince misconstrues the issue; his claims for unlawful arrest

and excessive force are not properly analyzed under the Due Process Clause.

The Fourth Amendment governs claims of unlawful arrest, not the Fourteenth

Amendment’s Due Process Clause. See Berg v. Cnty. of Allegheny, 219 F.3d 261, 268–69

4

(3d Cir. 2000); DeLade v. Cargan, 972 F.3d 207, 210 (3d Cir. 2020). And the Supreme

Court has held that “all claims that law enforcement officers have used excessive force—

deadly or not—in the course of an arrest . . . should be analyzed under the Fourth Amend-

ment and its ‘reasonableness’ standard, rather than under a ‘substantive due process’ ap-

proach.” Graham v. Connor, 490 U.S. 386, 395 (1989). Here, Vince’s claims of unlawful

arrest and excessive force fall squarely under the Fourth Amendment. Accordingly, the

District Court did not err in dismissing Vince’s Fourteenth Amendment claim.

B. THE FOURTH AMENDMENT

Vince alleges two Fourth Amendment violations: unlawful arrest and excessive

force. The District Court found Vince’s allegations for excessive force to be “threadbare.”

JA10. We agree.

To determine if police conduct constitutes excessive force, we consider whether the

force used was “‘objectively reasonable’ in light of the facts and circumstances confronting

[the officers], without regard to their underlying intent or motivation.” Graham, 490 U.S

at 397. Here, Vince alleges that he was physically restrained by handcuffs in a hot car for

3–4 hours while the officers verified his assertion that his warrant had been lifted. He does

not allege that complained to the officers of discomfort from the handcuffs or the temper-

ature in the car. Thus, the District Court did not err in concluding that the complaint failed

to state a Fourth Amendment claim for excessive force. See Kopec v. Tate, 361 F.3d 772,

776–77 (3d Cir. 2004) (concluding that handcuffing can be unreasonable if it was done

unnecessarily or excessively).

5

The District Court also properly dismissed Vince’s claim of unlawful arrest under

the Fourth Amendment. An officer sued under Section 1983 is entitled to qualified im-

munity unless he (1) violated a constitutional right that (2) was clearly established when

he acted. George v. Rehiel, 738 F.3d 562, 571–72 (3d Cir. 2013).

We begin and end our analysis on the first prong: whether Vince plausibly alleges

a violation of his Fourth Amendment rights. He does not. The Fourth Amendment protects

persons from “unreasonable searches and seizures” and prohibits arrests without probable

cause. U.S. Const. amend. IV; see Orsatti v. N.J. State Police, 71 F.3d 480, 482 (3d Cir.

1995). To determine whether an action was reasonable, we ask whether “the circum-

stances, viewed objectively, justify [the challenged] action.” Ashcroft v. al-Kidd, 563 U.S.

731, 736 (2011) (citing Scott v. United States, 436 U.S. 128, 138 (1978)). And probable

cause exists when “reasonably trustworthy information or circumstances within a police

officer’s knowledge are sufficient to warrant a person of reasonable caution to conclude

that an offense has been committed by the person being arrested.” United States v. Myers,

308 F.3d 251, 255 (3d Cir. 2002).

We have generally extended qualified immunity to officers who make an arrest

based on an objectively reasonable belief that there is a valid warrant, as long as it is rea-

sonable in light of the relevant circumstances. See Berg, 219 F.3d at 273. Here, the offic-

ers’ belief that there was a valid bench warrant gave them “reasonably trustworthy infor-

mation,” and thus, probable cause to arrest Vince. When Vince provided documentation

that the warrant had been lifted, the officers confirmed the information and released him,

which was reasonable under the circumstances. Therefore, the arrest was reasonable under

6

the Fourth Amendment and no violation occurred. The District Court committed no error

in dismissing Vince’s Section 1983 claim for unlawful arrest under the Fourth Amendment.

IV. LEAVE TO AMEND

If a complaint is subject to a Rule 12(b)(6) dismissal, a district court must permit

the plaintiff leave to amend unless amendment would be inequitable or futile. See Phillips,

515 F.3d at 245. The District Court concluded that amendment to the complaint would be

futile because Vince is currently represented by the same counsel who communicated with

officers at the scene and directed Vince’s wife to retrieve documents from the Luzerne

County Courthouse. We agree that because of counsel’s involvement with the underlying

incident, any facts plausibly stating either an excessive force or unlawful arrest claim

would have been alleged in the initial complaint. Thus, the District Court committed no

error.

*****

For the foregoing reasons, we will AFFIRM.

7

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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