Background
Plaintiff Susan Lloyd sued various defendants including a veterinary clinic, its staff, a law firm, and the Uwchlan Township Police Department following the death of her service dog and the deletion of her comments from a police Facebook page. The district court granted motions to dismiss and for summary judgment, finding that Lloyd failed to state claims against private parties and lacked evidence of personal involvement or municipal policy against the police.
The court’s reasoning
The court affirmed that sovereign immunity bars claims against the Commonwealth and the Board. It held that private attorneys and veterinarians are not state actors for Section one thousand nine hundred eighty-three purposes absent a conspiracy. Regarding the police department, the court found that Lloyd failed to adduce evidence that officers were personally responsible for deleting comments or blocking her account. The court also affirmed the rejection of the Monell claim because Lloyd identified no policy, custom, or failure to train.
What it means going forward
The decision reinforces the requirement that plaintiffs in civil rights cases must prove personal involvement by individual defendants and the existence of a municipal policy to hold a government entity liable.