Kegerise v. Susquehanna Township School District
2016 WL 407348, 321 F.R.D. 121 (2016)
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Rule of Law:
Under Federal Rule of Civil Procedure 8(b), a responsive pleading must directly address every allegation by either admitting it, denying it, or stating a lack of sufficient knowledge. A party cannot refuse to respond by claiming an allegation is a 'conclusion of law,' nor claim a lack of knowledge about information that is within its personal knowledge or is reasonably accessible.
Facts:
- Dr. Susan M. Kegerise served as the superintendent of the Susquehanna Township School District.
- In 2013, a high school gym teacher was transferred to an elementary school.
- School Board member Jesse Rawls, Sr. allegedly believed the transfer was discriminatory and told the teachers' union president that the transfer should be 'grieved.'
- On a separate occasion, Rawls allegedly visited the District Middle School and High School without giving prior notice to the administration.
- At a public school board meeting, Rawls accused Kegerise of nepotism, suggesting it as grounds to not renew her contract.
- Following this accusation, the School District conducted a special investigation that cost in excess of $15,000.
- The investigation ultimately cleared Dr. Kegerise of any wrongdoing.
- Kegerise's employment as superintendent was terminated, leading her to file a lawsuit.
Procedural Posture:
- Dr. Susan M. Kegerise sued the Susquehanna Township School District and three of its board members in the U.S. District Court for the Middle District of Pennsylvania, a federal trial court.
- Kegerise filed a third amended complaint.
- The defendants filed an answer to the third amended complaint.
- Kegerise filed a motion for judgment on the pleadings, arguing that the defendants' answer was legally insufficient under Fed. R. Civ. P. 8(b).
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Issue:
Under Federal Rule of Civil Procedure 8(b), is an answer to a complaint legally sufficient if it: (1) fails to deny all parts of an allegation not explicitly admitted; (2) responds to certain allegations by stating they are 'conclusions of law' requiring no response; and (3) claims a lack of knowledge about facts that are within the responding party's personal knowledge or are reasonably accessible?
Opinions:
Majority - William W. Caldwell
No, the answer is not legally sufficient. Under Federal Rule of Civil Procedure 8(b), a responsive pleading must directly address each allegation, and the defendants' answer failed to do so in three distinct ways. First, when denying only part of an allegation under Rule 8(b)(4), a party must explicitly admit the part that is true and 'deny the rest'; the defendants improperly left portions of allegations unaddressed. Second, Rule 8(b) does not permit a party to refuse to respond to an allegation by labeling it a 'conclusion of law'; the rule provides only three valid responses: admit, deny, or state a lack of sufficient information. Third, a party cannot claim a lack of knowledge under Rule 8(b)(5) about matters that are within its personal knowledge or reasonably accessible, such as a defendant's own actions or information contained in the school district's own records. Because the defendants' responses were defective, they will be ordered to file an amended answer.
Analysis:
This decision reinforces the strict pleading requirements of Federal Rule of Civil Procedure 8(b), clarifying that evasive or incomplete answers are impermissible. It specifically rejects the common but improper litigation tactic of refusing to respond to an allegation by deeming it a 'conclusion of law.' The opinion serves as a practical reminder to litigators that every allegation in a complaint requires a direct and good-faith response. By granting leave to amend rather than deeming the allegations admitted, the court demonstrates a preference for deciding cases on their substantive merits over resolving them on procedural technicalities, while still upholding the integrity of the pleading rules.
