The U.S. Court of Appeals for the Third Circuit affirmed the dismissal of a civil rights lawsuit filed by Dale Morgan against multiple Centre County law enforcement agencies in a non-precedential opinion issued Jan. 12, 2026.
The case, *Dale Morgan v. Centre County* (3d Cir. 2026), involved Morgan's claims under 42 U.S.C. § 1983 against several defendants, including Centre County, Pennsylvania State Trooper Michael D. Brown, Centre County District Attorney Bernie Cantorna, the Spring Township Police Department, and Spring Township Police Officer Luke Nelson.
The underlying incident occurred in January 2019 when a suspect in an identity-theft ring rented a car and turned it over to Horace Henry to drive. When a Pennsylvania State Trooper stopped the rental car for traffic violations, Henry presented a fake driver's license that bore his photograph but contained Morgan's name and other identifying information.
According to the court opinion, the state trooper believed the license was genuine and issued traffic violations based on the false identification. The trooper did not discover the fraudulent nature of the license during the traffic stop, which ultimately led to complications for Morgan.
Morgan filed his federal civil rights lawsuit in the U.S. District Court for the Middle District of Pennsylvania in 2023, designated as case number 4:23-cv-00872. The case was assigned to District Judge Matthew W. Brann, who issued three orders related to the dismissal of Morgan's claims.
The Third Circuit panel, consisting of Chief Judge Chagares and Circuit Judges Freeman and Bove, heard the appeal under Third Circuit Local Appellate Rule 34.1(a). The case was submitted to the court on Dec. 4, 2025, following briefing by the parties.
In the opinion authored by Circuit Judge Freeman, the appellate court affirmed all three district court orders that resulted in the dismissal of Morgan's Section 1983 claims. The court's decision was issued as a non-precedential opinion, meaning it does not constitute binding precedent for future cases under the Third Circuit's Internal Operating Procedures.
Section 1983 claims allow individuals to sue state and local government officials for violations of constitutional rights committed under color of state law. These cases often involve allegations of civil rights violations by law enforcement officers, government employees, or other officials acting in their official capacity.
The case illustrates the complex legal issues that can arise when identity theft intersects with law enforcement activities. When criminals use stolen personal information during encounters with police, innocent individuals like Morgan may face various consequences, including erroneous records in law enforcement databases and potential civil rights violations.
Morgan's lawsuit named multiple defendants across different law enforcement agencies in Centre County, Pennsylvania. The defendants included individual officers, supervisory personnel, and the agencies themselves. The inclusion of both state and local law enforcement officials suggests the case may have involved coordination between different agencies or overlapping jurisdictions.
The identity theft scheme that precipitated the case appears to have been sophisticated, involving the creation of fake identification documents that combined stolen personal information with different photographs. Such schemes can create significant problems for victims, who may find themselves associated with criminal activity or traffic violations they did not commit.
The district court's dismissal of Morgan's claims, which was upheld by the Third Circuit, suggests that the legal standards for establishing liability under Section 1983 were not met in this case. Civil rights plaintiffs must typically demonstrate that government officials violated clearly established constitutional or federal rights while acting under color of state law.
The appellate court's decision to issue a non-precedential opinion indicates that the legal principles applied were well-established and did not require the development of new precedent. Non-precedential opinions are commonly used for cases that involve routine application of existing law to specific factual circumstances.
The case highlights the challenges faced by identity theft victims in seeking legal remedies when law enforcement actions are based on fraudulent information provided by criminals. While the specific grounds for dismissal are not detailed in the available court documents, the outcome suggests that establishing liability against law enforcement officials in such circumstances can be difficult under current legal standards.
The Third Circuit's affirmance of the district court's dismissal orders effectively concludes Morgan's federal civil rights lawsuit against the Centre County defendants. The decision represents the final resolution of the case unless Morgan seeks further appellate review, though the prospects for such review would depend on the specific legal issues involved and whether they meet the standards for discretionary appeals.