The U.S. Court of Appeals for the Third Circuit issued a non-precedential opinion Monday affirming the dismissal of a civil rights lawsuit filed by pro se plaintiff Abrahim Fata against Charles Lang and Martha Lang. The three-judge panel, consisting of Circuit Judges Krause, Matey, and Bove, summarily affirmed the U.S. District Court for the Eastern District of Pennsylvania's order dismissing Fata's amended complaint.
The case, *Abrahim Fata v. Charles Lang; Martha Lang* (No. 25-1886), originated in December 2024 when Fata filed his civil rights complaint in the Eastern District of Pennsylvania. District Judge Mitchell S. Goldberg presided over the lower court proceedings, which were designated as Civil Action No. 5:24-cv-06934.
According to the Third Circuit's per curiam opinion filed Jan. 6, Fata's complaint contained multiple categories of legal claims. The plaintiff raised federal constitutional and civil rights claims, state tort claims, and allegations that the defendants had violated multiple federal criminal statutes. Central to Fata's case were allegations that the defendants' actions assisted a conspiracy to cover up the sexual abuse of his son in 2016.
Fata proceeded in forma pauperis, meaning he was permitted to file his lawsuit without paying standard court fees due to financial hardship. The district court granted Fata's application to proceed under this provision, which allows indigent litigants access to federal courts. However, federal law under 28 U.S.C. § 1915(e)(2)(B) permits courts to dismiss in forma pauperis cases that are frivolous, malicious, or fail to state a claim upon which relief can be granted.
The district court exercised this authority and dismissed Fata's conspiracy allegations as frivolous pursuant to the federal statute. While the Third Circuit's opinion does not detail the specific reasoning behind the district court's frivolity determination, such findings typically indicate that the allegations lack any arguable basis in law or fact.
The procedural posture of the case demonstrates the federal courts' gatekeeping function in screening civil rights litigation filed by pro se plaintiffs. The Third Circuit considered the appeal for possible dismissal under 28 U.S.C. § 1915(e)(2)(B) or summary action pursuant to Third Circuit Local Appellate Rule 27.4 and Internal Operating Procedure 10.6. These procedures allow the appeals court to resolve cases expeditiously when they present no substantial legal questions or when the result is obvious.
The case was submitted to the three-judge panel on Oct. 16, 2025, and the court's opinion was filed approximately two and half months later. The relatively quick turnaround reflects the summary nature of the proceedings and the court's determination that the appeal lacked merit requiring extensive briefing or oral argument.
The Third Circuit's decision to summarily affirm indicates the appeals court found no reversible error in the district court's handling of the case. Summary affirmance is appropriate when the district court's judgment is clearly correct and the appeal presents no substantial question worthy of further consideration. This disposition allows appellate courts to manage their caseloads efficiently while ensuring that meritorious appeals receive full consideration.
The opinion is designated as "NOT PRECEDENTIAL," meaning it does not establish binding legal authority for future cases. This designation is common for summary dispositions and cases involving routine application of established legal principles. The Third Circuit's Internal Operating Procedure 5.7 specifically states that such dispositions do not constitute binding precedent.
Pro se civil rights litigation presents ongoing challenges for federal courts, which must balance access to justice for unrepresented plaintiffs with the need to screen frivolous or legally insufficient claims. The in forma pauperis statute provides an important mechanism for this screening function, allowing courts to dismiss cases that fail to meet basic legal standards without requiring defendants to respond.
The case illustrates the procedural safeguards built into the federal court system to prevent abuse of civil rights statutes while preserving meaningful access for legitimate claims. Courts must carefully evaluate pro se complaints to determine whether they state plausible legal claims, even when the pleadings may be inartfully drafted or legally unsophisticated.
Fata's appeal appears to have concluded with the Third Circuit's summary affirmance, as the opinion provides no indication of further proceedings. The appellate court's brief treatment of the case suggests that Fata's arguments on appeal failed to demonstrate any error in the district court's legal analysis or factual determinations.
The underlying facts regarding the alleged conspiracy to cover up sexual abuse remain largely undeveloped in the available court records. The Third Circuit's opinion focuses primarily on the procedural aspects of the case rather than the substantive allegations, reflecting the court's determination that the legal issues were straightforward and required no extended analysis.