Summary
This Report and Recommendation from the United States District Court for the Middle District of Pennsylvania addresses a pro se civil rights action brought by an incarcerated plaintiff alleging wrongful denial of bail and racial discrimination. The magistrate judge analyzes motions to dismiss filed by a police commissioner and a magisterial district judge, evaluating defenses including Eleventh Amendment immunity, absolute judicial immunity, and qualified immunity. Concluding that the defendants are entitled to their respective immunities and that the plaintiff failed to state viable claims, the report recommends granting both motions to dismiss.
Topics
Practice areas
Questions Presented
- Whether Defendant Clancy is entitled to Eleventh Amendment immunity in her official capacity.
- Whether Defendant Clancy is entitled to judicial immunity in her individual capacity.
- Whether Defendant Muldrow is entitled to qualified immunity on his alleged Eighth Amendment bail‑interference claim.
- Whether the alleged conspiracy claim is sufficiently pleaded.
- Whether the due‑process claim is sufficiently pleaded.
- Whether the equal‑protection claim is sufficiently pleaded.
Holdings
- Defendant Clancy is shielded by Eleventh Amendment immunity; the claim against her in her official capacity must be dismissed without prejudice.
- Defendant Clancy is entitled to absolute judicial immunity; the claim against her in her individual capacity must be dismissed with prejudice.
- Defendant Muldrow is entitled to qualified immunity; the Eighth Amendment claim is dismissed with prejudice.
- The conspiracy claim is dismissed without prejudice; plaintiff may amend to provide more factual detail.
- The due‑process claim is dismissed without prejudice; plaintiff may amend.
- The equal‑protection claim is dismissed without prejudice; plaintiff may amend.
Key quotations
“The Eleventh Amendment to the United States Constitution precludes private individuals from bringing suit against a state in federal court.” (N/A)
“Judges handle complicated cases with complex and polarizing issues: without judicial immunity, courts would anticipate an “avalanche of suits” and that it may lead to judges shying away from difficult rulings.” (N/A)
Factual background
Donte Darrell Parrish, a pro se incarcerated defendant, was arraigned on April 19, 2022, and denied bail. He alleges that York City Police Commissioner Mike Muldrow called Magisterial Judge Jennifer Clancy before the arraignment, influencing her decision to deny bail. Parrish also alleges a pattern of racial discrimination in bail decisions in York County.
Procedural history
Plaintiff filed the complaint on April 18, 2024. The court certified the complaint, assigned the case to various magistrate judges, and ultimately issued a Report and Recommendation on July 24, 2025 recommending dismissal of the claims based on Eleventh Amendment immunity, judicial immunity, and qualified immunity, with leave to amend certain claims.
Remand instructions
Plaintiff is granted thirty (30) days to file an amended complaint addressing the conspiracy, due‑process, equal‑protection, and state‑law claims, and to comply with Rule 8 requirements.