Valentin v. Cartegena

On December 7, 1984, Jesus Valentin was shot and killed by Hiram Cartagena, a Pennsylvania State Police Officer. On November 18, 1986, Carmen Valentin, as administrator of her son’s estate and in her own right, commenced an action for wrongful death and the alleged violation of her son’s civil rights. One of the defendants named in the action was Cyril Laffey, a former acting Commissioner of the Pennsylvania State Police. When service of the complaint was attempted upon Laffey, it was discovered that he was deceased, having died on November 30, 1984, seven days before plaintiff’s decedent was…