Michael Allen Moorefield, II, as executor and trustee of the Michael Allen...

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA MICHAEL ALLEN MOOREFIELD, II, as ) executor and trustee of the MICHAEL ) ALLEN MOOREFIELD II LIVING ) No. 2:25-cv-650 ESTATE TR., ) ) ) District Judge Robert J. Colville Plaintiff, ) ) Magistrate Judge Patricia L. Dodge v. ) ) INTERNAL REVENUE SERVICE, et al., ) ) Defendants. ) )

ORDER OF COURT Currently pending before the Court is the Report and Recommendation (ECF No. 15) filed by the Honorable Patricia L. Dodge in the above-captioned matter. Judge Dodge’s August 12, 2025 Report and Recommendation recommends that the Court dismiss Plaintiff’s Complaint with prejudice pursuant to 18 U.S.C. § 1915(e)(2)(B) because the Complaint is frivolous, fails to state a claim upon which relief could be granted, and seeks relief against a defendant who is immune from such relief. Objections to the Report and Recommendation were due by August 26, 2025.

Plaintiff filed timely Objections (ECF No. 17) to the Report and Recommendation on August 25, 2025. Plaintiff has also filed several other documents and motions, each of which the undersigned has reviewed and none of which assert any argument that would materially alter the undersigned’s decision to accept and adopt Judge Dodge’s recommendation. This matter is ripe for disposition.

Objections to a magistrate judge’s disposition of a dispositive matter are subject to de novo review before the district judge. 28 U.S.C. § 636(b)(1)(B)-(C); Fed. R. Civ. P. 72(b)(3). The reviewing district court must make a de novo determination of those portions of the magistrate judge’s report and recommendation to which objections are made. Id. Following de novo review, “[t]he district judge may accept, reject, or modify the recommended disposition; receive further evidence; or return the matter to the magistrate judge with instructions.” Fed. R. Civ. P. 72(b)(3).

The United States Court of Appeals for the Third Circuit has explained that, “even absent objections to the report and recommendation, a district court should ‘afford some level of review to dispositive legal issues raised by the report,’” and has “described this level of review as ‘reasoned consideration.’” Equal Employment Opportunity Comm’n v. City of Long Branch, 866 F.3d 93, 100 (3d Cir. 2017) (quoting Henderson v. Carlson, 812 F.2d 874, 878 (3d Cir. 1987)).

Upon consideration of Judge Dodge’s Report and Recommendation, Plaintiff’s Objections to the Report and Recommendation, and following review of all relevant docket entries, it is hereby ORDERED as follows: The Court agrees with the thorough and well-reasoned analysis set forth in Judge Dodge’s Report and Recommendation, and the Court accepts and adopts Judge Dodge’s Report and Recommendation in its entirety as the opinion of the Court with respect to Plaintiff’s Complaint.

The undersigned agrees with Judge Dodge that Plaintiff’s Complaint fails to state a claim, seeks relief from an immune defendant, and is patently frivolous. Plaintiff’s Objections are overruled, as they advance no substantive argument that could support a different result. Plaintiff’s Complaint is dismissed with prejudice pursuant to 18 U.S.C. § 1915(e)(2)(B). The Clerk of Court shall mark this case as CLOSED. All remaining motions in this matter are hereby dismissed as moot.

BY THE COURT: /s/Robert J. Colville_______ Robert J. Colville United States District Judge DATED: January 15, 2026 cc: Michael Moorefield San Juan Ste 8 Mckeesport, PA 15133