Williams v. Assistant District Attorney John R. Canavan (2025)

Case details
Full caption
Robert W. Williams, Sr. v. Assistant District Attorney John R. Canavan, et al.
Country
United States
Jurisdiction
Federal
Decided
2025
Disposition
Dismissed
IN on R. in In W. ). on on W.ad 3). In an Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 1 of 12THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA ROBERT W. WILLIAMS, SR., No. 1 :25cv1016 his own behalf and as parent and next friend of R.W., Jr. , a minor, (Judge Munley) Plaintiff (Chief Magistrate Judge Bloom) V. ASSISTANT DISTRICT ATTORNEY JOHN CANAVAN, his individual capacity , et al . Defendant MEMORANDUM This case arises from a father and a son arguing , City of Harrisburg police officers intervening , and the Dauphin County District Attorney ' s Office pursuing charges against the father. response , the father , Plaintiff Robert Williams , Sr ~ filed this action under 42 U .S .C . § 1983 (" Section 1983 " He asserts claims his own behalf . He also asserts several claims behalf of his son , R . , Jr. (Doc . 1 ) . To address this conflict of interest , Williams, Sr . filed a motion fo r the appointment of a guardian !item along with hi s complaint. (Doc. making this request , he used generative artificial intelligence ("Al ") . The Al model , however , cited a real Fourth Circuit case for a proposition it does not contain. The Al model also declared that the case was on-point decision of the
is in an in C. 191on in 401 in an ). in in ~ Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 2 of 12Third Circuit , which it not. Under the law , a parent cannot represent his child federal court , even with the help of Al chatbot. The complaint this matter was referred to Chief Magistrate Judge Daryl F . Bloom for review pursuant to 28 U .S . § 5 (e)(2). Magistrate Judge Bloom reviewed the complaint and took judicial notice of the underlying criminal proceedings. His report and recommendation (" R&R " ) proposes dismissing the complaint without prejudice based the abstention doctrine set forth Younger v . Harris , U .S . 37 (1971 ) . (Doc . 5) . Williams , Sr . subsequently filed Al-aided objections to the R&R , which are 1 pending before the court . (Doc. 6) . Reviewing t he record de nova , the court will take a different approach to the R&R and the objections . Background and Procedural History Williams , Sr .' s objections do not challenge the background facts the R&R. Seeing no error , the court will adopt those facts as follows : 1 Williams ' s objections to the R&R include a table of contents and table of authorit i es corresponding to eleven - page document. (Doc . 6 at E CF p . 1-2 As filed , the objections are four (4) pages length and do not reference many of the cases listed the table of authorities . Additionally , the signature block contains space fo r a p h one number that has not been fully completed by the plaintiff , as if the Al model was provided the plaintiff ' s home • address and nothing more . at ECF p . 4 . 2
on in on C. 1-2) is in Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 3 of 12The complaint asserts that January 27 , 2025 , Defendants Appleby and Glunt arrived at Williams ' s home " following an internal family dispute[.]" Williams claims that Appleby unlawfully seized and assaulted him front of his minor son , and that he then instructed his son to go back inside the home . After Williams and his son both retreated into their home , Williams asserts that the officers , at the direction of ADA John Canavan , escalated the situation by coercing his son to open the door, resuming the encounter, and forcibly arresting Williams . Williams alleges that the officers brutally assaulted him , which his son captured video , and that the officers unlawfully detained his son while they were assaulting him. Based upon these allegations , Wi l liams asserts claims against the officers , the ADA , Dauphin County , and the City of Harrisburg pursuant to 42 U.S . § 1983, alleging violations of his Fourth, Fifth , Eighth , and Fourteenth Amendment rights , as well as related state law claims . As relief, Williams requests compensatory and punitive damages , a declaratory judgment , and attorney's fees. (Doc. 5 at (citations omitted , formatting modified). As alluded to above , Williams , Sr . currently being prosecuted the Dauphin County Court of Common Pleas for endangering the welfare of children , 3
~ 3. in ., CoCt. on in ad Jr. 3). be in In di5). in ~ 12Th$100 chldreenCase 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 4 of 12resisting arrest , and obstruction. at 2- (taking judicial notice of proceedings Commonwealth v . Williams, Sr No . CP - 22-CR-0001786-2025 (Dauphin . 2 Comm . Pl.)). Plaintiff filed the instant Section 1983 complaint June 6 , 2025 , and concurrently moved for leave to proceed forma pauperis (" IFP " ) using a handwritten form . (Doc. 2) . Noting Williams , Sr. ' s lack of employment , th e IFP 3 motion will be granted . Williams , Sr . also filed a motion to appoint a guardian litem for R.W . , (Doc . That motion will addressed detail below . The matter was subsequently assigned to Chief Magistrate Judge Bloom for review of the complaint pursuant to 28 U . S.C . § 1915(e)(2) . performing this screening , Chief Magistrate Judge Bloom observed the pending state prosecution and recommended that the court s miss the complaint wi t hout prejudice pursuant to Younger . (Doc. The logic behind the recommendation was to avoid interference with the plaintiff ' s stat e criminal charges currently pending Dauphin County . 2 See also https : //ujsportal.pacourts.us/Report/CpDocketSheet?docketNumber=CP-22-CR- 0001786-2025&dnh=wYezg1 Pqm9oK9Ew4rLXKVw%3D%3D (last accessed December , 2025 ) . 3 e cou rt also notes dramatic stylist i c differences between the IFP motion and Will i ams ' s othe r submiss i ons. That is , Williams ' s filings display a clear shift from a lay pleading style , (" 6 a month for property management. c urrently looking for a new opportunity .") , ( Doc . 2 , at 1 ) , to a polished , confident nar r ative , (" The officers then compounded the constitutional injur i es by unlawfully detaining the minor i , refusing t o allow him to - te r his own home. ") , (Doc . 1 , Comp I at 1 ) . 4
Sr. 1331In de C. in in 4, Id. 1. an in in in in Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 5 of 12Williams , filed objections to the R&R without delay - just two days later. (Doc. 6). Those objections are ripe for disposition. Jurisdiction The court has jurisdiction over the plaintiff ' s Section 1983 claims under 28 U.S.C . § . Standard of Review disposing of objections to a magistrate judge ' s report and recommendation, the district court must make a novo determination of those portions of the report against which objections are made. 28 U .S . § 636(b)(1)(c) ; see also Sullivan v . Cuyler , 723 F.2d 1077, 1085 (3d Cir. 1983) . The court may accept , reject , or modify , whole or part , the findings or recommendations made by the magistrate judge . Henderson v . Carlson , 812 F .2d 87 877 (3d Cir . 1987) . The district court judge may also receive further evidence or recommit the matter to the magistrate judge with instructions . Analysis The Objections Having observed uptick pro se litigants relying upon cut-and-paste Al outputs their legal filings, the court must address the machine: It served Williams , Sr . well some respects , but it did not serve him well others. 5
Sr. I. 1. Is ., been-a 2. if v. of at v. 800,817 permitted to proceedbe in an it inin is on is Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 6 of 12Williams , 's objections to the R&R begin as follows: INTRODUCTION Magistrate Judge Bloom's Report & Recommendation ("R&R," ECF 5) invokes Youngerv. Hanis, 401 U.S. 37 (1971) to recommend dismissal of this minor plaintiff's§ 1983 damages action. The recommendation is legally untenable for two i nd ependent reasons : Younger abstentJon categorically Inapplicable because Plaintiff ROBERT W. WILLIAMS, JR. (" R.W Jr. " ) is not - and never has party to the pending state prosecution against his father . Post-Sprint precedent confines Younger to si tuat i ons where the federal plaintiff is before the state tribunal. Even abstention were conceivable, Supreme Court and Third-Circuit authority (Deakins , Williams Red Bank) forbid dismissal damages claims ; the Court may, most , enter a stay . Because federal courts have a " virtually unflagging obligation · to exercise the jurisdiction Congress confers , Colorado River Water Conservation Dist. United States, 424 U.S. (1976) , the R&R must be rejected and this action . (Doc. 6). These objections are thought-provoking ; however , they will not addressed as filed. Doing so would put this case a box that Al service reasoned should be . Judges do not always think probabilities or algorithms. To start , neither the R&R nor the objections contemplate a conspicuous issue: Williams , Sr. simultaneously charged with endangering the welfare of his son and advancing Section 1983 claims for money damages his son ' s behalf. With the objections , he also trying to save his son ' s claims from dismissal. The court cannot disregard this practice. 6
an by ad ad order-to is in an FED. R. P. an an 3d FED. R. ad In is in is ," 3d ad ." kt in is in kt Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 7 of 12The Federal Rules of Civil Procedure provide that: A minor or incompetent person who does not have a duly appointed representative may sue a next friend or by a guardian litem. The court must appoint a guardian litem - or issue another appropriate protect a minor or incompetent person who unrepresented action . CIv . 17(c)(2) . The above rule imposes " obligation to issue appropriate order " to protect a minor ' s interests . Powell v . Symons , 680 F. 301, 307 (3d Cir. 2012) (quoting CIv. P . 17(c)(2)) . This obligation led the court to review the separate motion for appointment of a guardian litem. doing so , the plaintiff's Al usage became apparent. This where Al did not serve him well. Specifically , Section 1.2 of the motion, which entitled " Third Circuit Precedent Williams , Sr . cites " Doe v . Public Citizen , 749 F. 246 , 254 (3d Cir. 2014). " (Doc. 3 at 2) . Referencing that case , he argues: " The Third Circuit has emphasized that Guardian Litem appointment serves dual purposes: protecting the minor ' s substantive rights and ensuring the integrity of judicial proceedings at 2 . Williams , Sr . further argues: " The court ' s analysis Doe establishes that appointment particularly crucial civil rights cases where complex constitutional issues require sophisticated legal analysis and strategic case development. " 7
v. isin thad 3d in an by by kl is by is in by alMav. 11 ngpaper-whether by ngit-an .. an .. by by FED. P. 11 Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 8 of 12Doe Public Citizen , the world populated by humans , a Fourth Circuit case dealing with matters wholly unrelated to e appointment of a guardian litem . 749 F. 246 (4th Cir . 2014). The case concerns public access t o judicial records a lawsuit filed against the United States Consumer Product Safety Commission and appeal public interest groups seeking disclosure . The specific page misrepresented Williams , Sr . contains part of Judge Henry F . Floyd ' s analysis of the Consumer Product Safety Improvement Act of 2008. at 254 . This a serious error W i lliams , Sr . While the court directed to give pro se litigants "gr eater leeway " some respects , especially when interpreting their pleadings , pro se litigants cannot flout the rules -" they must abide the same rules that apply to l other litigants. " l a Crown Bay Marina, Inc. , 704 F.3d 239, 2 45 (3d Cir. 2013) . Rule covers Al hallucinations: By presenting to the court a plead i , written motion , or other signing , fil i , subm i tting , or later advocating . unrepresented party certifies that to the best of the person's knowledge , information , and bel i ef , formed after inquiry reasonable under the circumstances: . the claims , defenses , and other legal contentions are warranted existing law or a nonfrivolous argument for extending , modifying, or reversing existing law or for establishing new law[ . ] R . CIv . (b)(2) . 8
11 an FED. 11 In an 2. In is in by v. 1991 ). Sr. on in id. in in Sr. in on Sr. ad 17 Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 9 of 12Rule violations permit the imposition of sanctions after notice and opportunity to respond. R . CIv. P . (c). light of the circumstances, the court need not escalate the situation. Some might see irony with this particular Al hallucination . The court sees unwary user trying out "free" publicly available Al tools, which tout their ability to conduct in-depth research. R.W. Jr.'s Claims Will Be Dismissed Without Prejudice The above discussion brings the court back around to one of the main issues. the federal courts , "parties may plead and conduct their own cases personally[.]" 28 U.S.C. § 1654. However, a nonlawyer parent not entitled to play the role of attorney for his children federal court. Osei-Afriyie Osei- Afriyie Med . Coll. of Pennsylvania, 937 F.2d 876, 882 (3d Cir . Consequently , to the extent that Williams , attempts to bring any claims behalf of R.W. , Jr. the complaint, he cannot represent his son prose. See at 882-83. As this case presents itself, R.W. , Jr . appears to be the alleged victim the criminal case against the plaintiff the Dauphin County Court of Common Pleas. Williams, also appears to have placed the success of his son ' s civil rights claims the hands of a chatbot. By using Al to frame the legal narrative behalf of his son, Williams, has already overstepped. After careful consideration , appointing a guardian litem does not solve the issue. Williams, Sr . has asserted that R.W. , Jr . was years old as of June 9
18 .'is v. S. 2701221 L. Ed. v. ., on 18, by In on in 3. in In is Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 10 of 122025. (Doc . 3) . Therefore , if R.W. , Jr. has not already turned at the time of this decision , he will shortly. For that reason , the way to protect R.W. , Jr s interests to dismiss his Section 1983 claims against the defendants without prejudice. See Grizzell San Elijo Elementary Sch. , 110 F.4th 1177 , 1179 (9th Cir . 2024) , cert . denied , 145 Ct. , 2d 966 (2025) ; ltiowe Robert Wood Johnson Univ. Hosp . Hamilton , 556 F . App'x 124 , 125 (3d Cir. 2014) (non - precedential) . If R.W Jr . wishes , he may bring any claims through his own counsel or his own behalf when he turns if he has not had a birthday since the motion was filed six (6) months ago. As for the misrepresentations of the law noted the court , Williams , Sr . will be warned . the future , any unchecked reliance Al by the plaintiff will result sanctions , up to and including striking pleadings and dismissing claims with prejudice. Williams, Sr.'s Claims Will Be Stayed Williams , Sr . has also raised objections regarding the proposed dismissal of his own Section 1983 claims . Plaintiff argues that he should be heard now , or the alternative , that his civil rights claims must be stayed rather than dismissed. this instance , it prudent to gr ant Williams , Sr.'s request to stay the action rather than dismiss his claims without prejudice. See Hook v . Pike Cnty., 10
No. Pav. v. ., F. 811 v. No. (MD. Pa. 19No. 2021 (M. D. Pa. ). in on W.be be Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 11 of 123:23-CV-1204, 2024 WL 3237142, at *5-*8 (M.D. . June 28, 2024) (Mariani , J.) (citing Williams Hepting, 844 F. 2d 138 , 144-45 (3d Cir . 1988); Howard New Jersey Div. of Youth & Fam . Servs 398 App'x 807 , (3d Cir. 2010)) ; see also Fleming Yates, 1 : 21-CV-349, 2021 WL 6622489, at *6 . Apr. , 2021), report and recommendation adopted , CV 1:21- 349, WL 5833441 Dec. 9 , 2021 The court generally grants such requests made by counsel Section 1983 matters when their clients ' criminal cases remain pending . Based the stay , the case will be closed for administrative purposes. Williams , Sr . will be directed to file a report with the court every forty-five (45) days regarding the status of state court proceedings. Conclusion For the reasons set forth above , the court acknowledges Williams , Sr.'s objections to the R&R but will not grant or deny them . Given the unusual circumstances , the court will not adopt the R&R . Rather , upon de nova review , R . , Jr . 's claims against the defendants will dismissed without prejudice . Williams , Sr . ' s claims against the defendants will not dismissed. The court will grant plaintiff's request to stay his claims pending the conclusion of his criminal case . The court will impose conditions 1 1
Sr.in Case 1:25-cv-01016-JKM Document 9 Filed 12/15/25 Page 12 of 12upon Williams , ' s conduct this litigation . His IFP motion will be granted. The other pending motions will be denied as moot. An appropriate order follows. 12
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