BAUM v. GILES

CourtDistrict Court, M.D. Georgia
DecidedSeptember 12, 2025
Docket5:25-cv-00316
StatusUnknown

This text of BAUM v. GILES (BAUM v. GILES) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BAUM v. GILES, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION AMY BAUM, Plaintiff, v. CIVIL ACTION NO. ALAN GILES, ARTISAN AND 5:25-cv-00316-TES TRUCKERS CASUALTY COMPANY, EMPIRE FREIGHT SYSTEMS, and WEST CARGO, INC., Defendants.

ORDER GRANTING PLAINTIFF’S MOTION TO REMAND

Before the Court is Plaintiff’s Motion to Remand [Doc. 4] this case to the State Court of Bibb County, Georgia. Upon a review of the record and applicable law, the Court GRANTS Plaintiff’s Motion to Remand as explained below. A. Factual Background Defendants removed the above-captioned case to this Court on July 23, 2025, based on diversity jurisdiction under 28 U.S.C. § 1441(b). [Doc. 1, p. 1].1 Plaintiff originally filed suit against Defendants in the State Court of Bibb County, Georgia, on June 12, 2024. [Doc. 1-2, p. 3]. In her Complaint, Plaintiff alleges that “[o]n or about June 28, 2022 . . . Defendant Giles negligently operated a [tractor trailer], proximately and foreseeably causing a

1 This case does not present a federal question under 28 U.S.C. § 1331. collision with a vehicle being lawfully occupied and operated by . . . Plaintiff,” causing her to suffer “serious personal injuries, [and] incur[] medical expenses in excess of

$64,084.49, as well as lost wages in excess of $1.00.” [Id. at 5]. Defendants removed the case based on Plaintiff’s $1,000,000 demand and the most recent offer from Defendants’ insurer. [Doc. 13, p. 5]; [Doc. 1]; see Ashmeade v. Farmers Ins. Exch., No. 5:15-CV-533-OC-

34PRL, 2016 WL 1743457, at *2 (M.D. Fla. May 3, 2016) (“[i]n determining whether the amount in controversy has been met following removal, a court may consider settlement or demand letters”) (citing AAA Abachman v. Stanley Steemer Intern., Inc., F. App’x 864,

866 (11th Cir. 2008)). Plaintiff admits that her pleadings were “potentially” removable but argues that Defendants’ removal was not proper under 28 U.S.C. § 1446(b)(3). [Doc. 4, ¶ 4]. B. The Removal Standard

Removal is proper for “any civil action brought in a State court of which the district courts of the United States have original jurisdiction[.]” 28 U.S.C. § 1441(a). Defendants may remove based on 28 U.S.C. § 1332’s diversity jurisdiction. Id. at § 1441(b). To properly

remove a case, a defendant must file a notice of removal “within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based[.]” Id. at § 1446(b)(1); see also id. at § 1446(b)(2)(B). Furthermore, “[i]f defendants are served at

different times, and a later-served defendant files a notice of removal, any earlier-served defendant may consent to the removal even though that earlier-served defendant did not previously initiate or consent to the removal.” 28 U.S.C. § 1446(b)(2)(C).

Since Defendants removed this case from the State Court of Bibb County, Georgia, the Court looks to Georgia law for the applicable pre-removal service of process standard. White v. Capio Partners, LLC, No. 1:15-CV-120, 2015 WL 5944943, at *2 (S.D. Ga. Oct. 13,

2015) (citing Rentz v. Swift Transp. Co., 185 F.R.D. 693, 696 (M.D. Ga. 1998)). Under Georgia law, a plaintiff must serve the summons and complaint together. O.C.G.A. § 9-11-4(e). In actions against a corporation:

[i]f the action is against a foreign corporation doing business in this state without authorization to transact business in this state that has a managing agent or against a nonresident individual, partnership, joint-stock company, or association doing business in this state that has a managing agent, [service is to be made] to such agent, or to a registered agent designated for service of process. O.C.G.A. § 9-11-4(e)(2)(A).2 Additionally, Georgia has specific service of process rules for some defendants. For example, Georgia’s Nonresident Motorist Act has specific service of process rules for nonresident motor carriers. O.C.G.A. § 40-1-117(a). Under § 40-1-117(a),

2 Defendants cited O.C.G.A. § 9-11-4(e)(1)(A) in their Response to the Plaintiff’s Motion to Remand. [Doc. 14, p. 4]. However, Defendants failed to include the first part of § 9-11-4(e)(1)(A) in their Response, which qualifies the entire section. The excluded material reads, in part, “[i]f the action is against a corporation incorporated or domesticated under the laws of this state or a foreign corporation authorized to transact business in this state . . . .” O.C.G.A. § 9-11-4(e)(1)(A). Defendants have failed to plead or offer into the record any evidence that Defendant West Cargo, Inc., is “authorized to transact business in this state.” Id. Furthermore, this Court’s own search of Georgia’s public business records failed to produce such authorization. Bottom line, the section Defendants cited just doesn’t apply. Each nonresident motor carrier shall . . . designate and maintain in this state an agent or agents upon whom may be served all summonses or other lawful processes in any action or proceeding against such motor carrier growing out of its carrier operations; and service of process upon or acceptance or acknowledgment of such service by any such agent shall have the same legal force and validity as if duly served upon such nonresident carrier personally . . . Upon failure of any nonresident motor carrier to file such designation with the state revenue commissioner or to maintain such an agent in this state at the address given, such nonresident carrier shall be conclusively deemed to have designated the Secretary of State and his or her successors in office as such agent; and service of process upon or acceptance or acknowledgment of such service by the Secretary of State shall have the same legal force and validity as if duly served upon such nonresident carrier personally, provided that notice of such service and a copy of the process are immediately sent by registered or certified mail or statutory overnight delivery, return receipt requested, by the Secretary of State or his or her successor in office to such nonresident carrier, if its address be known. Service of such process upon the Secretary of State shall be made by delivering to his or her office two copies of such process with a fee of $10.00.

C. Plaintiff’s Motion to Remand [Doc. 4] In her Motion to Remand, Plaintiff agrees with Defendants that the parties are diverse,3 and the pleadings are “potentially” removable. See [Doc. 4, ¶¶ 1, 4]; [Doc. 13, pp. 5, 7]. Instead, Plaintiff states that removal was not proper under 28 U.S.C. § 1446(b)(3). [Doc. 4, ¶ 1].

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BAUM v. GILES, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baum-v-giles-gamd-2025.