Dylan Alexander Carr v. Deputy Mathew S. Lunardini

Summary

The United States District Court for the Western District of Pennsylvania grants a motion to dismiss Dylan Alexander Carr’s amended civil-rights complaint against Allegheny County Deputy Mathew S. Lunardini. The court holds that the facts alleged established probable cause as a matter of law for Carr’s arrest after photographing areas inside the Allegheny County Family Law Center, even if the statute’s application was ultimately debatable. The court dismisses Carr’s federal and Pennsylvania false-arrest and malicious-prosecution claims with prejudice.

Holdings

1. Carr failed to plausibly allege that Lunardini acted without probable cause. The facts known to the officer would have warranted a reasonable belief that photographing inside the court-related facility's lobby violated 18 Pa. Cons. Stat. § 5103.1, even if the statute's ultimate scope was debatable.
2. Carr's state-law claims failed because each relevant claim required the absence of probable cause, and the pleaded facts established probable cause as a matter of law.
3. Dismissal with prejudice was appropriate because amendment would be futile after the court determined that probable cause existed as a matter of law.

Questions Presented

1. Whether Carr plausibly alleged that Deputy Lunardini arrested and prosecuted him without probable cause, supporting Fourth Amendment false-arrest and malicious-prosecution claims under 42 U.S.C. § 1983.
2. Whether the facts alleged established probable cause as a matter of law despite uncertainty about whether 18 Pa. Cons. Stat. § 5103.1 applied to the Family Law Center lobby.
3. Whether Carr's Pennsylvania false-arrest, false-imprisonment, and malicious-prosecution claims failed because probable cause existed.
4. Whether dismissal with prejudice was proper because amendment would be futile.

Disposition

dismissed