SCRANTON – A federal judge has granted the Pennsylvania State Police’s motion for summary judgment in connection with a contractual claim brought by a man who alleged he provided information critical to the capture of a cop killer in 2014, and the case will now be directed to a Monroe County court.
A July 19 memorandum opinion from U.S. Magistrate Judge Martin C. Carlson saw plaintiff Edward M. Robl’s case against the Pennsylvania State Police end its journey in federal court, with its remaining state-law claim now heading to the Monroe County Court of Common Pleas.
“This case arises out of the investigation into the Sept. 12, 2014 sniper attack upon the Pennsylvania State Police Blooming Grove barracks, which resulted in the death of one Pennsylvania State Police trooper and serious injuries to a second trooper. In the wake of this murderous assault, Eric Frein was identified as a suspect in this slaying and numerous law enforcement agencies, including the Federal Bureau of Investigation, offered rewards for information leading to Frein’s apprehension,” Carlson said.
“In his pro se complaint, Edward M. Robl alleges that he is entitled to this reward money because, on or about Sept. 18, 2014, he provided information to the Pennsylvania State Police that he believes led directly to the arrest of Eric Frein some six weeks later, on Oct. 30, 2014. While Robl’s pro se complaint is not entirely pellucid on this point, it appears that he is bringing a contractual claim against Pennsylvania State Police for recovery of this reward, treating the offer of a reward as a unilateral contract he believes he fulfilled by providing information which led to Frein’s arrest and conviction.”
Along with the Pennsylvania State Police, Robl’s complaint originally named the FBI and Pennsylvania Crime Stoppers as defendants, though both were later dismissed from the action in May 2021 and April 2022, respectively.
As a result, all that remained in the lawsuit were state law contract claims by a Pennsylvania resident against the state police, who moved for summary judgment based upon a jurisdictional argument – asserting that federal courts are courts of limited jurisdiction, and our jurisdiction does not extend to state law disputes between citizens of the same state, Carlson said.
“Fairly construed, Mr. Robl’s complaint appears to allege a claim against the Pennsylvania State Police for recovery of a reward offered by that agency in the Eric Frein case. While the precise legal theory of recovery is somewhat vague in Robl’s pro se pleading, we agree that, as a general rule, the offer of a reward for performing a specified act, like providing information leading to the arrest and conviction of a catching a criminal, is deemed an offer of a unilateral contract,” Carlson stated.
“Therefore, we deem Mr. Robl’s claim in this case against the Pennsylvania State Police to sound in contract. Thus, with respect to Pennsylvania State Police, presently all that remains in this lawsuit are state law contract claims by a Pennsylvania resident against a Pennsylvania organizational entity. Construed in this fashion, we are compelled to agree that Robl’s complaint against the Pennsylvania State Police faces an insurmountable jurisdictional obstacle in this court. Robl simply brings state law breach of contract claims in federal court. However, the plaintiff may not assert federal jurisdiction over these state claims, since we can only exercise federal jurisdiction over such state law claims in ‘civil actions where the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is between citizens of different states.”
Yet, while these allegations do not show grounds giving rise to subject matter jurisdiction in federal court, Carlson added this does not mean that Robl has no legal remedies available to him.
“The plaintiff may return to state court and pursue these claims in the state court system. The state court certainly stands ready to hear Robl’s state law claims. Indeed, the plaintiff has asked that we remand his case to state court, and nothing in the state police’s motion, which simply questions whether we have subject matter jurisdiction, raises a principled objection to a dismissal order, coupled with a remand to state court,” Carlson said.
“In fact, our lack of subject matter jurisdiction seems to compel a remand of the case to state court under 28 U.S.C. Section 1447(c), which provides that: ‘If at any time before final judgment it appears that the district court lacks subject matter jurisdiction, the case shall be remanded. Simply put, we no longer have subject matter jurisdiction over this dispute. Accordingly, because we are powerless to entertain Robl’s claim in this court, that claim will be dismissed without prejudice to the remand of this case to state court.”
U.S. District Court for the Middle District of Pennsylvania case 3:20-cv-00343
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nick.malfitano@therecordinc.com