Jahlee is a member of the Professional Liability Department where he focuses his practice in the areas of employment law, civil rights, and municipal liability. Jahlee has represented public and private employers in wrongful discharge, employment discrimination and defamation claims from administrative proceedings through trial. In addition, Jahlee has provided guidance and advice to employers concerning employment-related matters.
Prior to joining Marshall Dennehey, Jahlee was an Attorney Advisor for a municipal police department where he was accountable for their Office of Professional Responsibility. In that capacity, Jahlee guided the department on issues concerning labor relations, contract disputes, defensive litigation and internal affairs investigations and drafted policies and procedures. He also worked as a Prosecutor in the Philadelphia District Attorney's Office. There, Jahlee prosecuted dozens of jury trials and hundreds of bench trials. In addition, he was assigned to the Special Investigation Unit (SIU) which investigated and prosecuted cases that involved public corruption and police misconduct.
Jahlee is very active within his community as demonstrated through his several prominent leadership roles in Philadelphia non-profit organizations and legal associations. An alumnus of Leadership Philadelphia, Jahlee previously served as Chair of the Citizen’s Police Oversight Commission, and he currently sits on two non-profit boards including the Philadelphia City Institute and the Board of Trustees for the Independence Charter School West and is a member of the Philadelphia Bar Association’s Board of Governors. He is a Past President of the Barristers’ Association of Philadelphia. Notably, Jahlee was recognized by The Philadelphia Tribune as one of Philadelphia's most influential African Americans.
Jahlee received his juris doctor from Widener University School of Law, where he was a member of the Alternative Dispute Resolution team. In addition, Jahlee was a part of Widener's Frederick Douglas Mock Trial team and won the Philadelphia regional competition. Jahlee has a Master's Degree in Organizational Development and Leadership and graduated from Temple University with a Bachelor of Arts in Criminal Justice. Based upon his experience and skill, Jahlee was admitted to the United States Supreme Court Bar in 2024. He is also admitted to practice in Pennsylvania and New Jersey.
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Case Law Alerts
No Relation Back: District Court Bars Substitution of John Doe Defendants After Statute of Limitations in § 1983 Opiate Withdrawal Death Case
January 1, 2026
The estate of an incarcerated decedent filed a complaint against the correctional facility, the warden of the facility and “John Doe” correctional officers on January 31, 2024. The complaint stemmed from the incarcerated decedent’s February 1, 2022, death due to complications associated with opiate withdrawal. The plaintiff’s claims included a § 1983 claim of deliberate indifference, alleging that the incarcerated decedent died based on his underlying drug withdrawal. On June 4, 2025, the plaintiff filed an amended complaint, where they identified for the first time, correctional officers and supervisors as named defendants. As a result, the newly named defendants filed a motion to dismiss the amended complaint on the basis that the statute of limitations barred the plaintiff from substituting the John Doe defendants. The District Court agreed and dismissed the plaintiff’s amended complaint against the newly added correctional officers. In granting motion to dismiss, the District Court held that the plaintiff’s claims were barred by Pennsylvania’s two-year statute of limitation. In objecting to the motion to dismiss, the plaintiff raised two arguments: (1) there was “good cause” to extend the relation-back period to encompass adding newly named defendants; and (2) that because the newly named defendants were supervisory defendants, they shared “identity of interest” with the original named defendants and could be added as defendants. The court quickly dispelled the plaintiff’s argument that good cause existed to allow the substitution of John Doe defendants more than a year after the passing of the statute of limitations. The court found that the plaintiff did not make any effort to identify the newly added parties prior to filing the initial lawsuit. Additionally, the plaintiff exhausted the statute of limitations before even attempting to substitute the John Doe defendants. The court also discredited plaintiff’s “relation back” argument, noting that in order for this doctrine to apply, there must be a showing that: (1) the claim set forth in the amended pleading arose out of the initial conduct/transaction alleged in the original complaint; (2) the parties received adequate notice of the institution of the proceedings; and (3) the parties sought to be added knew that they would be defendants in the lawsuit. The court relied heavily on the fact that plaintiff did not demonstrate that the parties had actual or constructive notice of the suit within 90 days of the filing of the original complaint. The court delineated that constructive notice can be established where parties share an attorney or had “identity of interest.” Identity of interest generally means that the parties are so closely related in their business operations or other activities that the institution of an action against one serves to provide notice of the litigation of another. The court held that non-management employees do not share a sufficient nexus of interest with their employer to establish identity of interest. Additionally, the court considered the fact that the original defendants and the newly added defendants did not share the same attorneys so F.R.Civ.P. 15(c) did not trigger constructive notice. Here, plaintiff failed to show that the parties were on notice of the institution of the original proceeding, or that the parties knew that they would be defendants in plaintiff’s litigation. Based on that, the court granted the defendants’ motion to dismiss.
Defense Digest
A Shift in Wrongful Incarceration and Malicious Prosecution Lawsuits: Multi-Million Dollar Settlements Turned into Case Dismissals
December 1, 2025
Key Points: The pleading standard for wrongful incarceration and malicious prosecution cases may gradually be shifting to require more specific allegations in order to establish such claims. The Constitution does not provide individuals with a right to have an “adequate” investigation conducted. In recent years, there has been a drastic shift in the way that local prosecutor’s offices handle wrongful incarceration cases, specifically as it relates to overturned homicide convictions. For instance, since 2020, the City of Philadelphia has paid in excess of $20 million in fees for settlement of lawsuits stemming from wrongful incarcerations. Separately, juries have awarded plaintiffs more than $10 million in wrongful conviction cases. These wrongful incarceration lawsuits have been fueled, in part, by efforts by prosecutors to hold police officers accountable for engaging in unethical practices while investigating crimes. In 2021, the Philadelphia District Attorney’s Office charged three long-retired homicide detectives with perjury and related charges in connection with their testimony in a criminal trial. The underlying criminal trial stemmed from the rape and murder of an elderly woman, which occurred in 1991. The defendant in that case was convicted, in part, based on a confession that he provided. The defendant was later granted a new trial, and the homicide detectives provided testimony concerning the methods used to obtain the confession. The defendant was acquitted. Following the acquittal, the Philadelphia District Attorney’s Office arrested the homicide detectives based on their testimony at the re-trial. Two of the three detectives were later convicted of perjury and related offenses. The criminal defendant later filed a civil rights lawsuit, which settled for millions of dollars. In another case, a former Philadelphia homicide detective, James Pitts, was arrested and convicted of felony charges for perjury and obstruction of justice in connection with the 2010 interrogation of a homicide suspect. In that case, Pitts investigated a gruesome robbery/homicide and developed O.O. as a suspect. Pitts interrogated O.O. and obtained a confession. The confession was later used to prosecute and convict O.O. for homicide and related charges. In 2021, O.O.’s conviction was overturned, in part, based on the District Attorney’s finding that O.O.’s confession was coerced. In 2022, Pitts was arrested for perjury and related charges following a grand jury indictment. Pitts was later convicted and sentenced to more than two years’ incarceration. Following Pitts’ incarceration, several civil lawsuits were filed against him, alleging he coerced the plaintiffs into providing false confessions and maliciously prosecuted them for crimes they did not commit. Prior to the case of Wallace v. City of Phila. et al., 2025 WL 2935248 (E.D. Pa. Oct. 15, 2021), the District Court routinely allowed those lawsuits to advance through discovery simply based on an allegation that law enforcement officials obtained coerced confessions and/or physically assaulted criminal defendants. However, in Wallace, District Court Judge Karen Marston ruled that barebones claims of malicious prosecution, in the absence of something more, do not establish a viable malicious prosecution or wrongful incarceration claim. In Wallace, the plaintiff brought claims of malicious prosecution, deprivation of due process, violation of the plaintiff’s right against self-incrimination, civil conspiracy, failure to intervene, Section 1983 Monell violations, and state law malicious prosecution. In the complaint, Wallace alleged that, in 2012, he was wrongfully convicted of second-degree murder based on Pitts’ wrongful conduct, including obtaining a false confession. In that case, Wallace claimed that he was merely present in a home when his associate shot and killed an off-duty police officer. Wallace claimed that following the shooting, Pitts obtained a coerced confession from him while he was heavily sedated and that Pitts also forcibly requested that bullet fragments be retrieved from the plaintiff’s body, against his will. Wallace was subsequently convicted of homicide and related charges and served more than a decade in prison before his conviction was overturned. In response to the complaint, Pitts filed a motion to dismiss on several grounds including: (1) the complaint failed to establish that he engaged in conduct that amounted to malicious prosecution; (2) the plaintiff failed to establish that Pitts fabricated evidence; (3) the plaintiff failed to establish that exculpatory evidence was deliberately withheld or suppressed; (4) the plaintiff did not establish that an adequate investigation was not conducted: (5) the plaintiff did not establish a violation of the 5th Amendment right against self-incrimination; (6) the plaintiff failed to establish a civil conspiracy; and (7) the plaintiff failed to establish a claim of failure to intervene. In granting the motion to dismiss in its entirety, Judge Marston zeroed in on the malicious prosecution claim and found that, in order to establish such a claim, a plaintiff must establish the following: (1) the government initiated a criminal proceeding; (2) the criminal proceeding ended in the plaintiff’s favor; (3) the proceeding was initiated without probable cause; (4) the government acted maliciously or for a purpose other than bringing the plaintiff to justice; and (5) the plaintiff suffered a deprivation of liberty consistent with a legal seizure. Wallace, 2025 WL 2935248, at *7 (E.D. Pa. Oct. 15, 2025). In dismissing the claims, the court emphasized that the plaintiff did not put forth any allegations to suggest that Pitts knowingly provided false information to prosecutors in order to secure a conviction. In drawing this distinction, Judge Marston doubled down on a well-established proposition that a mere allegation of coercion, without more, is a legal conclusion that ordinarily will not survive a motion to dismiss. Id. at *8 (E.D. Pa. Oct. 15, 2025). Last, Judge Marston clearly delineated that the Constitution does not provide individuals with a so-called right to have an adequate investigation conducted. Id. Defense Digest, Vol. 31, No. 4, December 2025, is prepared by Marshall Dennehey to provide information on recent legal developments of interest to our readers. This publication is not intended to provide legal advice for a specific situation or to create an attorney-client relationship. ATTORNEY ADVERTISING pursuant to New York RPC 7.1. © 2025 Marshall Dennehey. All Rights Reserved. This article may not be reprinted without the express written permission of our firm. For reprints, contact tamontemuro@mdwcg.com.
