Carter v. Effingham County Sheriff's Department

CourtDistrict Court, S.D. Georgia
DecidedAugust 29, 2023
Docket4:22-cv-00288
StatusUnknown

This text of Carter v. Effingham County Sheriff's Department (Carter v. Effingham County Sheriff's Department) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carter v. Effingham County Sheriff's Department, (S.D. Ga. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION

GARY ANTHONY CARTER, JR.,) ) Plaintiff, ) ) v. ) CV422-288 ) WINSTON MOCK, and ) SERGEANT LOCKETT, ) ) Defendants. ) ORDER In April, the Court noted procedural missteps in this case. See generally doc. 39. Specifically, the Court noted that Defendant Lockett was in default. Doc. 39 at 2-3. The Court stayed all deadlines in the case for a limited period to permit proceedings on Lockett’s default. Id. at 6- 7. The Clerk was directed to enter a scheduling notice at the termination of that stay. See id. at 7. Lockett move to set aside her default. Doc. 43. During the pendency of the stay, Plaintiff filed multiple discovery related motions. See docs. 41, 44, 45 & 67. He also filed two motions to amend. Docs. 56 & 61. Although he has filed two motions related to Lockett’s default, neither specifically responds to her Motion to Set Aside Default. See doc. 57 & 58. That motion, therefore, stands unopposed. See S.D. Ga. L. Civ. R. 7.5.1 Defendant Mock has filed two motions to dismiss, docs. 46 & 47, to which Carter has responded, albeit only in a cursory

fashion, doc. 48 at 1. Finally, despite the Court’s instruction, no scheduling notice was entered at the termination of the stay. See

generally docket. Defendant Mock, based on a deadline imposed in a prior scheduling notice, now seeks to file an “out of time” Motion for Summary Judgment.” Doc. 72.

First, the Court must address Defendant Lockett’s status in this case. As the Court previously explained, because she failed to respond timely, she is in default, notwithstanding her appearance and assertion

of defenses. See doc. 39 at 2-3; see also doc. 40. The entry of default is not dispositive, however. “The court may set aside an entry of default for

1 Carter filed an ambiguous document titled “Motion to Dismiss Case Due to Default.” Doc. 58. It states: “Sergeant Juanita Lockett had counsel take her case in defense and the attorneys should have been able to respect the time limits set by the courts in advance.” Id. at 1. Charitably, that statement is a response to the Motion to Set Aside Default. To the extent that it was intended as a response, however, it does nothing to overcome the Motion’s showing of good cause to set aside the default, as discussed below. His suggestion that defendant has somehow defaulted “as a tactic to wait [him] out for an error on [his] behalf,” id., is nonsensical. Finally, his assertion that he is somehow entitled to relief against the individual defendants because unidentified Effingham County Jail staff have, allegedly, failed to forward the Court’s prior Order concerning payment of his filing fee, see id. (asserting the alleged failure “was a continued move to forfeit this action”), is meritless. Since it presents no cognizable request for relief, the Clerk is DIRECTED to TERMINATE the Motion. Doc. 58. good cause . . . .” Fed. R. Civ. P. 55(c). As this Court has previously explained:

While there is no precise formula for assessing “good cause”, courts commonly consider “whether the default was culpable or willful, whether setting it aside would prejudice the adversary, and whether the defaulting party presents a meritorious defense.” Compania Interamericana Exp.-Imp., S.A. v. Compania Dominicana de Aviacion, 88 F.3d 948, 951 (11th Cir.1996) (citations omitted). These factors are not talismanic, and other factors also may be relevant in making a good cause determination. Id. For example, an additional factor that may be relevant is whether the defaulting party acted promptly to correct the default. Id. (citing Dierschke v. O'Cheskey, 975 F.2d 181, 184 (5th Cir. 1992)). “Whatever factors are employed, the imperative is that they be regarded simply as a means of identifying circumstances which warrant the finding of ‘good cause’ to set aside a default.” Id.

Wortham v. Brown, 2015 WL 2152826, at *1 (S.D. Ga. May 7, 2015). The Court has discretion in applying the factors. See, e.g., Robinson v. United States, 734 F.2d 735, 739 (11th Cir. 1984) (“Action on a motion to set aside a default is within the discretion of the district court . . . .”). In determining whether a litigant has demonstrated sufficient good cause under Rule 55(c), the Court is mindful of the Eleventh Circuit’s “strong preference that cases be heard on the merits.” Perez v. Wells Fargo N.A., 774 F.3d 1329, 1342 (11th Cir. 2014) (internal citation and quotation omitted). Lockett has established good cause to set aside the default. Lockett’s Motion to Set Aside Default states that her failure to respond

“was the result of an inadvertent mistake by her counsel.” Doc. 43 at 2. Specifically, her counsel “erroneously calculated the applicable 60-day

deadline from the date of execution of the service waiver rather than from the date the service waiver was originally dated.” Id. at 3. She cites to specific authority that an identical mistake was not culpable or willful.

See id. (citing Schiavo v. LEB Solutions, LLC, 2020 WL 13389324, at *1 (M.D. Fla. July 14, 2020)). She has also made unrebutted showings of meritorious defenses and lack of prejudice.2 See id. at 3-4. Her Motion

to Set Aside Default is, therefore, GRANTED. Doc. 43. The next issue that the Court must address is Carter’s attempts to amend his Complaint. Since Carter has already amended his Complaint,

see docs. 1 & 12, he can only amend with the Court’s leave or the opposing parties’ written consent. See Fed. R. Civ. P. 15(a)(2). Carter’s first Motion to Amend seeks to add Effingham County Sheriff Jimmy

2 As discussed in Footnote 1 above, to the extent that Carter’s “Motion to Dismiss Case Due to Default,” doc. 58, was intended as a response to Lockett’s Motion to Set Aside Default, it does not present any meritorious argument against the analysis above. McDuffie and the Effingham County Board of Commissioners as defendants. See doc. 56. His second Motion to Amend seeks to add a

number of individual defendants who he alleges were involved in the failure to respond to his suicidal ideations. See doc. 61 at 2-3. Lockett

has responded in opposition to both motions, in part, by pointing out that the asserted “right to relief is either unclear or unstated.” See doc. 63 at 2; doc. 66 at 2. Lockett is correct.

The Eleventh Circuit has explained that “[w]hen moving the district court for leave to amend [a] complaint, the plaintiff must set forth the substance of the proposed amendment or attach a copy of the

proposed amendment to its motion. [Cit.] The substance of the proposed amendment serves as the functional equivalent of a copy of the proposed amendment it if is sufficient on its face to inform the Court of the

proposal.” Newton v. Duke Energy Fla., LLC, 895 F.3d 1270, 1277-78 (11th Cir. 2018) (internal quotation marks and citations omitted). Since Carter’s motions do not attach any proposed amended complaint, their

sufficiency depends upon whether they sufficiently “inform the Court of the proposal.” Id. They do not. In Newton, the Court of Appeals noted that the plaintiffs’ motion “merely hypothesizes, in broad strokes, the kind of amendments that [they] might have been able to make.” Id. at 1278. Carter’s first Motion states:

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Malowney v. Federal Collection Deposit Group
193 F.3d 1342 (Eleventh Circuit, 1999)
Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Clinton v. Jones
520 U.S. 681 (Supreme Court, 1997)
Joseph Patrick Robinson v. United States
734 F.2d 735 (Eleventh Circuit, 1984)
Enora Perez v. Wdlls Fargo N.A.
774 F.3d 1329 (Eleventh Circuit, 2014)
William B. Newton v. Duke Energy Florida, LLC
895 F.3d 1270 (Eleventh Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Carter v. Effingham County Sheriff's Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carter-v-effingham-county-sheriffs-department-gasd-2023.