The opinion
UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
KONSTANTINOS SGAGIAS, : CIV NO. 1:24-CV-1632
:
Plaintiff, :
:
v. : (Magistrate Judge Carlson)
:
NEWBERRY TOWNSHIP POLICE :
DEPARTMENT, et al. :
:
Defendants. :
MEMORANDUM OPINION
I. Statement of Facts and of the Case
Since initiating this case in September of 2024, the pro se plaintiff in this case,
Konstantinos Sgagias, has filed at least four versions of his complaint. Sgagias’s
third amended complaint, the operative pleading in this case, 1 brought civil rights
claims under 42 U.S.C. § 1983 against two institutional defendants, York County
and Newberry Township Police Department, as well as the York County District
Attorney, David Sunday, and a Newberry Township police officer, Lieutenant
1 As we noted in previously dismissing some of his claims, the plaintiff’s manner of
pleading runs afoul of Rule 15(a) which authorizes a party to amend his pleading
once as a matter of course within 21 days after serving it, or 21 days after service of
a dispositive motion or responsive pleading, whichever is earlier, Fed.R.Civ.P.
15(a)(1)(A) and (B), and “[i]n all other cases, a party may amend its pleading only
with the opposing party's written consent, or the court's leave,” which courts are to
freely give “when justice so requires,” Fed.R.Civ.P. 15(a)(2). Nonetheless, the
defendants have all directed their motions to dismiss at the third amended complaint,
(Doc. 22), which we have treated as the operative pleading in this case.
Braxton Ditty. (Doc. 22). He also alleged pendant state law claims of conversion,
false arrest, and abuse of process against the Newberry Township Police Department
and Lieutenant Ditty. (Id.)
On September 12, 2025, on motion by the defendants, we dismissed the
plaintiff’s claims against York County and York County District Attorney David
Sunday as well as the constitutional claims against Newberry Township Police
Department. (Doc. 48). Thus, the only remaining claims in this case are
constitutional violations of due process, false arrest, and unlawful seizure against
Defendant Ditty and state law tort claims against Lt. Ditty and the Newberry
Township Police Department.
The factual allegations which form the basis of these claims can be stated as
follows: According to the complaint, Sgagias’ claims originate from his 2018
purchase of a York County property at a tax sale which had previously operated as
an automotive salvage yard. (Doc. 22, ⁋⁋ 9-10). Prior to the plaintiff taking
possession of the property in 2022, Sgagias alleges that the former proprietor of the
salvage company, Emeka Kinglsey Oguejiofor, abandoned a 2015 Chevrolet
Camaro on the property. (Id. ⁋⁋ 10-13). Though not entirely clear from the face of
the complaint, it appears a legal battle ensued over whether Oguejiofor had
abandoned the Camaro and who was its rightful owner. (Id., ⁋⁋ 13-15). According
to the plaintiff, he legally possessed the Camaro pursuant to several Pennsylvania
court orders.2 (Id.)
On September 28, 2022, officers of the Newberry Township Police
Department, under the direction of Defendant Lieutenant Braxton Ditty, entered
Sgagias’ property to conduct a VIN check on the Camaro at which time Sgagias
alleges he presented the officers with the court orders proving the vehicle was
forfeited and lawfully in his possession. (Id., ⁋⁋ 16-17). Despite this documentation,
the officers removed the vehicle from the plaintiff’s property and returned it to
Oguejiofor. (Id., ⁋ 18). A few months later, on December 27, 2022, Lieutenant Ditty
charged the plaintiff with misdemeanor unauthorized use of a vehicle. (Id., ⁋ 19).
Despite this case remaining unresolved in state court at the time, in September
2024, Sgagias filed his complaint in federal court, alleging the defendants violated
his constitutional rights and committed state law torts when they removed the vehicle
from his property and initiated criminal charges against him. After dismissing some
of the claims and defendants, we stayed Sgagias’s remaining claims pending the
resolution of the state criminal case against Sgagias, which the plaintiff informed us
terminated in his favor when he was acquitted on November 5, 2025. (Doc. 59;
2 The attached exhibits that the plaintiff purports confirm his claims that he legally
possessed the vehicle are enigmatic in nature and, in our view, evidence only that
Oguejiofor and Sgagias were in a legal battle over its ownership. None of the
documents directly address ownership of, or mention, the Camaro.
Commonwealth v. Konstantinos G. Sgagias, Docket No. CP-67-CR-0000001978-
2023 (Pa. Com. Pl. – York Cnty.)). On December 23, 2025, we lifted the stay on the
plaintiff’s remaining claims against Defendants Ditty and Newberry Township
Police Department and the proceedings were reopened. (Doc. 61).
These remaining defendants have now moved to dismiss the plaintiff’s third
amended complaint, arguing that his claims fail as a matter of law. (Doc. 69). The
motion is fully briefed and ripe for disposition. (Docs. 70, 73).
As we have foreshadowed in denying the plaintiff’s repeated requests to
further amend his complaint, after a review of the pleadings in this case, we find that
Defendant Ditty is entitled to qualified immunity against any constitutional claims
lodged by the plaintiff. Moreover, we will decline to exercise jurisdiction over any
remaining state law claims against Defendants Ditty or the Newberry Township
Police Department and dismiss this case.
II. Discussion
A. Motions to Dismiss—Standard of Review.
A motion to dismiss under Rule 12(b)(6) tests the legal sufficiency of a
complaint. It is proper for the court to dismiss a complaint in accordance with Rule
12(b)(6) of the Federal Rules of Civil Procedure only if the complaint fails to state
a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). With respect to
this benchmark standard for legal sufficiency of a complaint, the United States Court
of Appeals for the Third Circuit has aptly noted the evolving standards governing
pleading practice in federal court, stating that:
Standards of pleading have been in the forefront of jurisprudence in
recent years. Beginning with the Supreme Court’s opinion in Bell
Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), continuing with our
opinion in Phillips [v. County of Allegheny, 515 F.3d 224, 230 (3d Cir.
2008)], and culminating recently with the Supreme Court’s decision in
Ashcroft v. Iqbal, BU.S.B, 129 S. Ct. 1937 (2009), pleading standards
have seemingly shifted from simple notice pleading to a more
heightened form of pleading, requiring a plaintiff to plead more than
the possibility of relief to survive a motion to dismiss.
Fowler v. UPMC Shadyside, 578 F.3d 203, 209-10 (3d Cir. 2009).
In considering whether a complaint fails to state a claim upon which relief
may be granted, the court must accept as true all allegations in the complaint and all
reasonable inferences that can be drawn therefrom are to be construed in the light
most favorable to the plaintiff. Jordan v. Fox, Rothschild, O’Brien & Frankel, Inc.,
20 F.3d 1250, 1261 (3d Cir. 1994). However, a court “need not credit a complaint’s
bald assertions or legal conclusions when deciding a motion to dismiss.” Morse v.
Lower Merion Sch. Dist., 132 F.3d 902, 906 (3d Cir. 1997). Additionally, a court
need not “assume that a . . . plaintiff can prove facts that the . . . plaintiff has not
alleged.” Associated Gen. Contractors of Cal. v. California State Council of
Carpenters, 459 U.S. 519, 526 (1983). As the Supreme Court held in Bell Atlantic
Corp. v. Twombly, 550 U.S. 544 (2007), in order to state a valid cause of action, a
plaintiff must provide some factual grounds for relief which “requires more than
labels and conclusions, and a formulaic recitation of the elements of a cause of
actions will not do.” Id. at 555. “Factual allegations must be enough to raise a right
to relief above the speculative level.” Id.
In keeping with the principles of Twombly, the Supreme Court has
underscored that a trial court must assess whether a complaint states facts upon
which relief can be granted when ruling on a motion to dismiss. In Ashcroft v. Iqbal,
556 U.S. 662 (2009), the Supreme Court held that, when considering a motion to
dismiss, a court should “begin by identifying pleadings that, because they are no
more than conclusions, are not entitled to the assumption of truth.” Id. at 679.
According to the Supreme Court, “[t]hreadbare recitals of the elements of a cause of
action, supported by mere conclusory statements, do not suffice.” Id. at 678. Rather,
in conducting a review of the adequacy of a complaint, the Supreme Court has
advised trial courts that they must:
[B]egin by identifying pleadings that because they are no more than
conclusions are not entitled to the assumption of truth. While legal
conclusions can provide the framework of a complaint, they must be
supported by factual allegations. When there are well-pleaded factual
allegations, a court should assume their veracity and then determine
whether they plausibly give rise to an entitlement to relief.
Id. at 679.
Thus, following Twombly and Iqbal, a well-pleaded complaint must contain
more than mere legal labels and conclusions; it must recite factual allegations
sufficient to raise the plaintiff’s claimed right to relief beyond the level of mere
speculation. As the United States Court of Appeals for the Third Circuit has stated:
[A]fter Iqbal, when presented with a motion to dismiss for failure to
state a claim, district courts should conduct a two-part analysis. First,
the factual and legal elements of a claim should be separated. The
District Court must accept all of the complaint’s well-pleaded facts as
true, but may disregard any legal conclusions. Second, a District Court
must then determine whether the facts alleged in the complaint are
sufficient to show that the plaintiff has a “plausible claim for relief.” In
other words, a complaint must do more than allege the plaintiff’s
entitlement to relief. A complaint has to “show” such an entitlement
with its facts.
Fowler, 578 F.3d at 210-11.
As the Court of Appeals has observed:
The Supreme Court in Twombly set forth the “plausibility” standard for
overcoming a motion to dismiss and refined this approach in Iqbal. The
plausibility standard requires the complaint to allege “enough facts to
state a claim to relief that is plausible on its face.” Twombly, 550 U.S.
at 570, 127 S. Ct. 1955. A complaint satisfies the plausibility standard
when the factual pleadings “allow[ ] the court to draw the reasonable
inference that the defendant is liable for the misconduct alleged.” Iqbal,
129 S. Ct. at 1949 (citing Twombly, 550 U.S. at 556, 127 S. Ct. 1955).
This standard requires showing “more than a sheer possibility that a
defendant has acted unlawfully.” Id. A complaint which pleads facts
“merely consistent with” a defendant’s liability, [ ] “stops short of the
line between possibility and plausibility of ‘entitlement of relief.’ ”
Burtch v. Milberg Factors, Inc., 662 F.3d 212, 220-21 (3d Cir. 2011), cert. denied,
132 S. Ct. 1861, 182 L.Ed.2d 644 (2012).
In practice, consideration of the legal sufficiency of a complaint entails a
three-step analysis:
First, the court must ‘tak[e] note of the elements a plaintiff must plead
to state a claim.’ Iqbal, 129 S. Ct. at 1947. Second, the court should
identify allegations that, ‘because they are no more than conclusions,
are not entitled to the assumption of truth.’ Id. at 1950. Finally, ‘where
there are well-pleaded factual allegations, a court should assume their
veracity and then determine whether they plausibly give rise to an
entitlement for relief.’ Id.
Santiago v. Warminster Twp., 629 F.3d 121, 130 (3d Cir. 2010).
In considering a motion to dismiss, the court generally relies on the complaint,
attached exhibits, and matters of public record. Sands v. McCormick, 502 F.3d 263,
268 (3d Cir. 2007). The court may also consider “undisputedly authentic
document[s] that a defendant attached as an exhibit to a motion to dismiss if the
plaintiff’s claims are based on the [attached] documents.” Pension Benefit Guar.
Corp. v. White Consol. Indus., 998 F.2d 1192, 1196 (3d Cir. 1993). Moreover,
“documents whose contents are alleged in the complaint and whose authenticity no
party questions, but which are not physically attached to the pleading, may be
considered.” Pryor v. Nat’l Collegiate Athletic Ass’n, 288 F.3d 548, 560 (3d Cir.
2002); see also U.S. Express Lines, Ltd. v. Higgins, 281 F.3d 382, 388 (3d Cir. 2002)
(holding that “[a]lthough a district court may not consider matters extraneous to the
pleadings, a document integral to or explicitly relied upon in the complaint may be
considered without converting the motion to dismiss in one for summary
judgment”). However, the court may not rely on other parts of the record in
determining a motion to dismiss, or when determining whether a proposed amended
complaint is futile because it fails to state a claim upon which relief may be granted.
Jordan v. Fox, Rothschild, O’Brien & Frankel, 20 F.3d 1250, 1261 (3d Cir. 1994).
It is against these legal guideposts that we assess the legal sufficiency of this
complaint.
B. The Motion to Dismiss Will Be Granted.3
1. Defendant Ditty is Entitled to Qualified Immunity from the
Constitutional Claims.
The plaintiff alleges Fourth Amendment and due process claims against
Defendant Ditty under 42 U.S.C. § 1983, arguing he arrested him and seized the
Camaro without probable cause or a warrant. For the defendant’s part, Lt. Ditty
argues he is immune from liability for these claims under the doctrine of qualified
immunity, since it was not clearly established that he would be violating the
plaintiff’s constitutional rights by relying upon the statements of Oguejiofor that the
3 Before engaging in the qualified immunity analysis which forms the basis of our
decision to dismiss the plaintiff’s claims, we address the plaintiff’s contention
throughout his brief in opposition to this motion to dismiss that “the Court already
denied dismissal of these claims and found Plaintiff’s allegations plausible” and thus
they must move forward under the law of the case doctrine. Quite the contrary, our
September 12, 2025, memorandum opinion dismissing some of the plaintiff’s claims
made clear that we abstained from ruling on the merits of these remaining claims
under the Younger abstention doctrine because they involved his unresolved state
criminal case. (Doc. 47). Thus, while at that juncture in September 2025 we declined
to dismiss these claims, we also did not address the merits of his claims against
Defendant Ditty or the state law claims. In fact, we foreshadowed our view that these
claims were, in fact, likely subject to qualified immunity protections in our decision
denying the plaintiff’s motion to further amend. (Doc. 60).
car was stolen and the title which purported to show Oguejiofor, and not Sgagias, as
the owner of the Camaro. We agree.
The doctrine of qualified immunity shields governmental officials from civil
liability so long as their conduct “does not violate clearly established statutory or
constitutional rights of which a reasonable person would have known.” Mullenix v.
Luna, 577 U.S. 7, 11 (2015). The qualified immunity inquiry has two parts. The first
asks whether the plaintiff has alleged sufficient facts to “make out a violation of a
constitutional right.” Pearson v. Callahan, 555 U.S. 223, 232 (2009). The second
question is “whether the right at issue was clearly established at the time of [the]
defendant's alleged misconduct.” Id. (internal quotation marks omitted). A court may
“exercise [its] sound discretion in deciding which of the two prongs of the qualified
immunity analysis” to address first “in light of the circumstances of the particular
case at hand.” Pearson, 555 U.S. at 236, 129 S.Ct. 808.
A right is clearly established if “every reasonable official would have
understood that what he is doing violates that right.” Mullenix, 577 U.S. at 11. To
be clearly established, there does not have to be a case that is directly on point, “but
existing precedent must have placed the statutory or constitutional question beyond
debate.” Id. (quoting Ashcroft v. Al-Kidd, 563 U.S. 731, 741 (2011)). In determining
whether a right is clearly established, courts must not define the right “at a high level
of generality.” Id. (quoting Al-Kidd, 563 U.S. at 742, 131 S.Ct. 2074.) Rather, the
analysis should focus on “whether the violative nature of particular conduct is clearly
established.” Id. (quoting Al-Kidd, 563 U.S. at 742). On this score, “[t]he relevant,
dispositive inquiry in determining whether a right is clearly established is whether it
would be clear to a reasonable officer that his conduct was unlawful in the situation
he confronted.” Saucier, 533 U.S. at 202. It is the plaintiff who bears the initial
burden of demonstrating that the constitutional right at issue was clearly established
at the time of the claimed violation. See Davis v. Scherer, 468 U.S. 183, 197 (1984)
(“A plaintiff who seeks damages for violation of constitutional or statutory rights
may overcome the defendant official's qualified immunity only by showing that
those rights were clearly established at the time of the conduct at issue.”); Sherwood
v. Mulvihill, 113 F.3d 396, 399 (3d Cir. 1997) (“Where a defendant asserts a
qualified immunity defense in a motion for summary judgment, the plaintiff bears
the initial burden of showing that the defendant's conduct violated some clearly
established statutory or constitutional right.”).
To determine whether a right is clearly established, the court may look to cases
from the Supreme Court, controlling circuit precedent, or “a robust consensus of
cases of persuasive authority” from other circuit courts. Porter v. Pa. Dep't of Corrs.,
974 F.3d 431, 449 (3d Cir. 2020) (quoting Barna v. Bd. of Sch. Dirs. of Panther
Valley Sch. Dist., 877 F.3d 136, 142 (3d Cir. 2017)). In rare cases, the unlawfulness
of a government official's conduct may be established from the obviously unlawful
nature of the defendant's conduct “even though existing precedent does not address
similar circumstances.” Wesby, 138 S. Ct. at 590 (citing Brosseau v. Haugen, 543
U.S. 194, 199 (2004)).
Against this standard, the plaintiff’s complaint does not allege sufficient facts
to make out a violation of a clearly established constitutional right. At the outset, an
essential element of his false arrest claim is the absence of probable cause. Kokinda
v. Breiner, 557 F. Supp. 2d 581, 592 (M.D. Pa. 2008) (citing Garcia v. County of
Bucks, 155 F. Supp. 2d 259, 265 (E.D. Pa. 2001) (“To maintain his false arrest
claims, a plaintiff must show that the arresting officer lacked probable cause to make
the arrest”). Probable cause to arrest exists “whenever 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.” U.S. v. Myers, 308 F.3d 251, 255 (3d Cir.
2002) (citing Beck v. Ohio, 379 U.S. 89, 91 (1964)). In conducting an inquiry into
whether probable cause to arrest existed, a court should consider the totality of the
circumstances presented, and “must assess the knowledge and information which
the officers possessed at the time of arrest, coupled with the factual occurrences
immediately precipitating the arrest.” United States v. Stubbs, 281 F.3d 109, 122 (3d
Cir. 2002).
Here, the exhibits attached to the plaintiff’s complaint indicate that Lt. Ditty
had probable cause to believe the Camaro belonged to Oguejiofor and Sgagias had
committed the crime charged. In fact, the title to the Camaro, which the plaintiff
purports proves he was the lawful owner of the Camaro at the time he was charged,
(Doc. 49-1, ⁋ 24), actually shows the exact opposite – that the title listed Emeka
Kinglsey Oguejiofor as the owner of the vehicle.4 (Doc. 49-5, at 3). Moreover, the
affidavit of probable cause notes that the Newberry Township Police Department
received a call from Oguejiofor reporting his vehicle stolen, and that the officers’
subsequent investigation revealed the car was registered to him. (Doc. 49-8, “After
running the VIN I was able to verify that the vehicle was in Mr. Oguejiofor’s
name.”).5 Given these facts, it cannot be said that the officers “violate[d] clearly
4 We decline the plaintiff’s offer to undertake an analysis of vehicle title law which
he purports shows this title was defective. As we have noted, we do not rely upon
the ultimate conclusion on the heavily disputed and litigated issue of the ownership
of the Camaro in concluding the defendant is entitled to qualified immunity but
instead conclude it was not clearly established as constitutionally violative for the
officer to rely on the car title revealing Oguejiofor’s name as the owner combined
with his statements to police that the vehicle was stolen in concluding probable cause
existed.
5 Further any substantive due process claim also fails under the more specific
provision rule. The Fourteenth Amendment guarantees that no state shall deprive
any person of life, liberty, and property without due process of law. U.S. Const.
amend. XIV. However, the more specific provision rule informs us that “if a
constitutional claim is covered by a specific constitutional provision, such as the
Fourth or Eighth Amendment, the claim must be analyzed under the standard
appropriate to that specific provision, not under the rubric of substantive due
process.” Betts v. New Castle Youth Dev. Ctr., 621 F.3d 249, 260 (3d Cir. 2010)
(quoting United States v. Lanier, 520 U.S. 259, 272 n.7, 117 S. Ct. 1219, 137 L. Ed.
2d 432 (1997)). Here, the plaintiff's due process claims arises from the very same
conduct upon which he bases his false arrest and unlawful seizure, which fall under
established statutory or constitutional rights of which a reasonable person would
have known.” Mullenix, 577 U.S. at 11, since the facts available to the officers at
the time showed Oguejiofor, who reported the vehicle stolen, was the registered
owner of the vehicle. This stubborn fact also entitles the plaintiff to qualified
immunity from any unlawful seizure claim since the facts in Lt. Ditty’s possession
at the time of the seizure reasonably showed Sgagias did not own the vehicle.6
Moreover, Sgagias’ ultimate acquittal on state charges is not the relevant
inquiry in determining whether the Lt. Ditty had probable cause at the time of the
plaintiff’s arrest. On this score, while the plaintiff points us to evidence upon which
he was acquitted at trial, as we recently explained to the plaintiff:
the Fourth Amendment's protections. In such instances, the more specific Fourth
Amendment claims control, and the general due process claim should be dismissed.
See Hitner v. Alshefski, 2020 WL 3288157, at *2 (M.D. Pa. 2020) (denying
Fourteenth Amendment Due Process claim based on allegations of First Amendment
access-to-courts and retaliation). To the extent he alleges a procedural due process
violation for the seizure of a property interest without due process, this would require
that Sgagias had a property interest in the Camaro, which we have concluded he
simply has not shown. Keller v. City of Scranton, No. CIV.A. 3:09-CV-2534, 2010
WL 2104665, at *3 (M.D. Pa. May 24, 2010) (“To establish a cause of action for a
procedural due process violation, a plaintiff must first prove that a person acting
under color of state law deprived him of a protected property interest; and second,
he must show that the procedures available to him failed to provide him with due
process of law”).
6 It is worth noting that there is still some ambiguity regarding the fate of the Camaro.
For example, whether Sgagias ever formally and unequivocally acquired title and
possession of the vehicle. Nonetheless, since we find Sgagias has not shown it was
clearly established Lt. Ditty could not rely on the registered owner of the vehicle in
determining ownership for the purposes of the seizure, those are issues the plaintiff
can work out in state court if he wishes to pursue his common law claims.
“Probable cause does not require the same type of specific evidence of
each element of the offense as would be needed to support a
conviction.” Adams v. Williams, 407 U.S. 143, 149, 92 S.Ct. 1921, 32
L.Ed.2d 612 (1972). Therefore, the evidentiary standard for probable
cause is significantly lower than the standard which is required for
conviction. See Michigan v. DeFillippo, 443 U.S. 31, 36, 99 S.Ct.
2627, 61 L.Ed.2d 343 (1979) (“We have made clear that the kinds and
degree of proof and the procedural requirements necessary for a
conviction are not prerequisites to a valid arrest.”) (citations omitted);
Wilson v. Russo, 212 F.3d 781, 789 (3d Cir.2000) (holding that
probable cause only requires a “fair probability” that a person
committed the relevant crime). An arrest was made with probable
cause if “at the moment the arrest was made . . . the facts and
circumstances within [the officers'] knowledge and of which they had
reasonably trustworthy information were sufficient to warrant a
prudent man in believing that [the suspect] had committed or was
committing an offense.” Beck v. Ohio, 379 U.S. 89, 91, 85 S.Ct. 223,
13 L.Ed.2d 142 (1964) (citations omitted). In other words, the
constitutional validity of the arrest does not depend on whether the
suspect actually committed any crime. Johnson v. Campbell, 332 F.3d
199, 211 (3d Cir.2003).
Wright v. City of Philadelphia, 409 F.3d 595, 602 (3d Cir. 2005). Thus, regardless
of the evidence of his acquittal at trial, the defendant was entitled to rely on the
vehicle title which was tied to the VIN of the vehicle and showed Oguejiofor’s name,
and not Sgagias’s, over the vague, piecemeal paperwork and regulatory context
Sgagias alleges demonstrates he was the legal owner of the vehicle at least for the
purposes of probable cause, which requires on a fair probability that a person
committed the relevant crime. Wilson, 212 F.3d at 789.
Ultimately, for purposes of qualified immunity, Sgagias has not shown, nor
can he show, cases from the Supreme Court, controlling circuit precedent, or “a
robust consensus of cases of persuasive authority” from other circuit courts, Porter
v. Pa. Dep't of Corrs., 974 F.3d 431, 449 (3d Cir. 2020) (quoting Barna v. Bd. of
Sch. Dirs. of Panther Valley Sch. Dist., 877 F.3d 136, 142 (3d Cir. 2017)), that the
rights he alleges the defendants violated in arresting him and seizing the Camaro
were clearly established.7 Instead, the defendants have highlighted Third Circuit
precedent upholding qualified immunity where officers formed probable cause to
arrest based solely upon statements of a party asserting a contrary interest in the
property, see Bailey v. Gibbons, 508 F. App'x 136, 138–39 (3d Cir. 2013) (“[E]ven
assuming that the Officers mistakenly arrested [the plaintiff] solely on the basis of
Gibbons' statements that he was the lawful owner, we cannot say that the Officers'
conduct violated clearly established law”), even where the officers who seized
personal property were mistaken about its true owner. See Keller v. City of Scranton,
No. 3:09-CV-2534, 2013 WL 1681524, at *5 (M.D. Pa. Apr. 17, 2013).8
7 While the plaintiff cites to Supreme Court cases, he does not explain how these
cases specifically show the defendants violated a clearly established right on the
facts of this case.
8 Further bolstering his entitlement to qualified immunity is the Third Circuit
precedent cited by the defendant which supports a presumption of qualified
immunity from false arrest charges where a police officer relies in good faith on a
prosecutor’s legal opinion that the arrest is warranted under the law. Kelly v.
Borough of Carlisle, 622 F.3d 248, 256 (3d Cir. 2010). It is clear from the face of
the complaint and attached exhibits that the decision to charge the plaintiff was made
in coordination with the District Attorney’s office based upon their investigation into
the disputed ownership of the Camaro. Moreover, the plaintiff has not overcome this
presumption by showing a reasonable officer would not have relied on the
prosecutor’s advice. Instead, the plaintiff argues only that Lt. Ditty withheld proof
2. We Decline to Exercise Supplemental Jurisdiction Over the
State Law Claims.
Finally, Sgagias also asserts state law claims of conversion, false arrest, and
abuse of process against Newberry Township Police Department and Lt. Ditty. On
this score, our disposition of the plaintiff's primary federal legal claims suggests the
appropriate course for the court to follow in addressing these ancillary state law
claims that the plaintiff may wish to pursue.
In a case such as this, where the jurisdiction of the federal court was premised
on alleged federal claims which are found to be subject to dismissal the proper course
generally is for “the court [to] decline to exercise supplemental jurisdiction over the
plaintiff's state law claims. 28 U.S.C. § 1367(c)(3) (“The district courts may decline
to exercise supplemental jurisdiction over a claim under subsection (a) if- ... the
district court has dismissed all claims over which it has original jurisdiction.”);
United Mine Workers v. Gibbs, 383 U.S. 715, 726, 86 S.Ct. 1130, 16 L.Ed.2d 218
(1966) (holding that when federal causes of action are dismissed, federal courts
should not separately entertain pendent state claims).” Bronson v. White, No. 05-
2150, 2007 WL 3033865, *13 (M.D. Pa. Oct. 15, 2007)(Caputo, J.)(adopting report
and recommendation dismissing ancillary malpractice claim against dentist); see
of his ownership, which we have concluded was at most equivocal as to what it
showed, from the prosecutors.
Ham v. Greer, 269 F. App'x 149, 151 (3d Cir. 2008) (“Because the District Court
appropriately dismissed [the inmate's] Bivens claims, no independent basis for
federal jurisdiction remains. In addition, the district court did not abuse its discretion
in declining to address the state law negligence claims. 28 U.S.C. § 1367(c)(3); see
United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 726, 86 S.Ct. 1130, 16 L.Ed.2d
218 (1966); Tully v. Mott Supermkts., Inc., 540 F.2d 187, 196 (3d Cir. 1976).”)
In short, after the dismissal of Sgagias’s federal claims, all that remains of this
lawsuit is a state tort case, which involves the resolution of a property and title
dispute. The resolution of these state torts is a state matter, governed by state law,
and should, therefore, be addressed by the state courts.
Therefore, consistent with the dictates of 28 U.S.C. § 1367(c)(3), which
provides that “[t]he district courts may decline to exercise supplemental jurisdiction
over a [state-law] claim . . . if the district court has dismissed all claims over which
it has original jurisdiction,” we decline to further exercise jurisdiction over these
state tort claims, and dismiss them without prejudice to renewal of this action in state
court if the plaintiff elects to do so.
An appropriate order follows.
S/ Martin C. Carlson
Martin C. Carlson
United States Magistrate Judge
Date: May 1, 2026