Jonathan Valentin v. Philadelphia County Sheriffs Department

── Jonathan Valentin v. Philadelphia County Sheriffs Department ── Court: Court of Appeals for the Third Circuit Date: May 14, 2026 Category: General NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________ No. 25-1120 __________ JONATHAN VALENTIN, Appellant v. PHILADELPHIA COUNTY SHERIFF’S DEPARTMENT; DEPUTY OFFICER MR. DEREK MURPHY, Badge No. 1609; DEPUTY OFFICER MS. AMANDA RODRIGUEZ, Badge No. 5535 ____________________________________ On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil Action No. 2:19-cv-01175) District Judge: Honorable Mitchell S. Goldberg ____________________________________ Submitted Pursuant to Third Circuit LAR 34.1(a) May 1, 2026 Before: MATEY, MONTGOMERY-REEVES, and NYGAARD, Circuit Judges (Opinion filed: May 14, 2026) ___________ OPINION * ___________ PER CURIAM * This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent.  Pro se appellant Jonathan Valentin appeals from the dismissal of his civil rights suit by the United States District Court for the Eastern District of Pennsylvania. For the reasons that follow, we will affirm the District Court’s order. Valentin filed suit in 2019 under 42 U.S.C. § 1983, alleging that his rights were violated during his 2017 arrest in Philadelphia Family Court. He named as defendants the Philadelphia County Sheriff’s Department, Officer Derek Murphy, and Officer Amada Rodriguez. 1 Valentin claims that Murphy grabbed his neck, placed him into a chokehold, and threw him into a wall. The defendants denied Valentin’s claims, submitted declarations by Murphy and Rodriguez, and moved for summary judgment. In 2022, the District Court granted the defendants’ summary judgment motion, ruling that Valentin failed to submit evidence to support his claims. Valentin appealed, and we affirmed in part, vacated in part, and remanded. Valentin v. Phila. Cnty. Sheriff's Dep't, No. 22-1527, 2023 WL 5607556 (3d Cir. Aug. 30, 2023) (non precedential). The three claims which survived summary judgment were excessive force under the Fourth Amendment, false arrest under the Fourth Amendment, and First Amendment retaliation. Id. at *5. Upon remand, Valentin “missed nearly every deadline” set by the District Court and “repeatedly filed frivolous Motions in an effort to delay his own trial.” On June 18, 2024, Valentin failed to appear for a status conference. On August 12, 2024, Valentin 1 Per the defendants’ filings, Rodriguez’s first name is not “Amanda,” as set forth in the case caption. 2 failed to file his pre-trial memorandum or motions in limine pursuant to the Court’s scheduling order. Because Valentin was not complying with deadlines, the Court was forced to postpone the original trial date of August 26, 2024. On September 10, 2024, Valentin failed to appear at a virtual settlement conference before a Magistrate Judge, despite written confirmation two days prior that he was aware of it. Valentin subsequently filed a motion to reschedule the settlement conference, and the Court granted it, postponing the second trial date of October 28, 2024, in order to do so. At a scheduling conference on November 4, 2024, Valentin confirmed that he would be available and ready for a trial in January 2025, and that he would be able to appear in person