Krista Mader v. Phamatech, Inc. and Responsible Employees, et al.

Summary

The United States District Court for the Western District of Pennsylvania granted Phamatech, Inc. and related defendants’ motion to dismiss Krista Mader’s amended complaint. The court held that Mader failed to sufficiently plead the defendants’ personal involvement or intentional disparate treatment supporting a Fourteenth Amendment equal protection claim based on the denial of a drug-test retest. The claims against the Phamatech defendants were dismissed with prejudice, while the court deferred consideration of the exhaustion defense.

Holdings

1. The amended complaint failed to plead the Phamatech defendants' personal involvement in the alleged constitutional deprivation because it alleged only that Phamatech informed Mader's family that the DOC had to request a retest, without alleging that the defendants participated in, directed, knew of, or acquiesced in the prison officials' conduct.
2. The amended complaint failed to state a class-of-one equal-protection claim against the Phamatech defendants because it did not plausibly allege intentional and arbitrary disparate treatment by those defendants.
3. Further amendment was futile, and the Fourteenth Amendment claims against the Phamatech defendants were properly dismissed with prejudice.

Questions Presented

1. Whether the amended complaint plausibly alleged that the Phamatech defendants were personally involved in depriving Mader of a constitutional right under 42 U.S.C. § 1983.
2. Whether the amended complaint stated a Fourteenth Amendment equal-protection claim under a class-of-one theory based on the alleged denial of a urine-sample retest.
3. Whether further amendment should be permitted after Mader had already amended her complaint.

Disposition

dismissed