COLEMAN v. NEW JERSEY TRANSIT (2020)

OPINION *

Ronnie Coleman, Jr. claims to have been physically harmed by several law enforcement officers, both during an altercation on a train operated by New Jersey Transit Corporation (NJ Transit) and during his subsequent detention at the Secaucus Junction Transit Station in Secaucus, New Jersey. Coleman sued only the entities he believed were responsible for his assailants and, therefore, his injuries: NJ Transit and the NJ Transit Police Department (collectively, Defendants).¹

Defendants responded with a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that as a matter of law they are not considered “person[s]” subject to suit under 42 U.S.C. § 1983, the federal civil rights statute. The District Court agreed, and concluded as well that any apparent state law claims raised by Coleman were equally defective as a matter of law. The District Court thus granted Defendants’ motion to dismiss.² This timely appeal followed.

We have jurisdiction under 28 U.S.C. § 1291. For a pro se civil rights action like this one, our rule is that “district courts must offer amendment—irrespective of whether it is requested—when dismissing a case for failure to state a claim unless doing so would be inequitable or futile.” Fletcher-Harlee Corp. v. Pote Concrete Contractors, Inc., 482 F.3d 247, 251 (3d Cir. 2007). The District Court does not appear to have considered whether an opportunity to amend could have benefited Coleman. Cf. Foman v. Davis, 371 U.S. 178, 182, 83 S.Ct. 227, 9 L.Ed.2d 222 (1962) (“[O]utright refusal to grant the leave without any justifying reason [i.e., inequity or futility] appearing for the denial is not an exercise of discretion; it is merely abuse of that discretion and inconsistent with the spirit of the Federal Rules.”). And, from our vantage point, it seems quite possible that an amended complaint could have set forth plausible claims under § 1983 against the individual law enforcement officers that Coleman made reference to in the original pleading.

Accordingly, we will vacate the District Court's judgment and remand for further proceedings consistent with this opinion.

FOOTNOTES

1.   Coleman also named “New Jersey Transit Corporate Headquarters” as a defendant, but that appears to be a redundancy.

2.   The District Court also denied as moot Coleman's motion for default judgment.

PER CURIAM