Crotts v. Freedom Mortgage Corporation

District Court, S.D. Texas·Decided July 8, 2025·No. 4:23-cv-04828·Unknown

Opinion

UNITED STATES DISTRICT COURT July 08, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION § Alan Nelson Crotts, § § Plaintiff, § § Civil Action No. 4:23-cv-04828 v. § § Freedom Mortgage Corporation, § Stanley Middleman, CEO and § Owner, and John Doe, Employee, § § Defendants. §

MEMORANDUM, RECOMMENDATION, AND ORDER Multiple motions are pending. First, Defendant Stanley Middleman, the CEO and Owner of Freedom Mortgage Corporation, has filed a motion to dismiss all claims for lack of personal jurisdiction and on the merits. See Dkt. 47. Middleman also moved to stay discovery pending resolution of his motion to dismiss. Dkt. 52. Plaintiff Alan Nelson Crotts has filed numerous motions for “judicial notice.” Dkt. 44, 50, 54. He also moved to reconsider the previous order denying Crotts’s motion to recuse the undersigned judge. See Dkt. 58. After carefully considering the motions, responses, replies, the record, and the applicable law, it is recommended that Middleman’s motion to dismiss (Dkt. 47) be granted, and that all remaining claims be dismissed for want of personal jurisdiction. It is ordered that (1) Crotts’s motions for judicial notice (Dkt. 44, 50, 54) and his motion for reconsideration (Dkt. 58) be denied, and (2) Middleman’s motion for stay of discovery (Dkt. 52) be granted.

Background The factual background to this mortgage dispute is not material to the issues addressed below. For present purposes, it suffices to note that the claims against Middleman are all that remains in this case. Middleman was

not properly served until after the claims against Freedom Mortgage were dismissed. Compare Dkt. 24 (August 26, 2024 order dismissing claims against Freedom Mortgage), with Dkt. 44-1 at 2 (December 10, 2024 substitute service on Middleman).

After Middleman was served, Crotts filed a motion requesting judicial notice that service had been effectuated. Dkt. 44. Middleman then filed a motion to dismiss all claims, partly based on lack of personal jurisdiction but also on the merits. See Dkt. 47. Crotts filed a response, Dkt. 51, and a separate

“Verified Motion for Judicial Notice of Relevant Adjudicative Facts,” Dkt. 50. Middleman moved to stay discovery pending the Court’s ruling on the motion to dismiss, Dkt. 52, which Crotts opposed, Dkt. 53; see also Dkt. 55 (Middleman’s reply).

On March 13, 2025, Crotts filed a “Verified Motion for Judicial Notice of Admissions by Middleman,” asserting that Middleman failed to provide timely responses to requests for admission that were served on January 30, 2025. Dkt. 54 at 2. Under the current docket control order, however, discovery closed on November 29, 2024. Dkt. 17 at 2. Crotts did not seek leave to propound

discovery on Middleman. On March 28, 2025, given the issues and motions in this case, the Court vacated all remaining deadlines for the pretrial order, docket call, and trial. Dkt. 57. Analysis

I. Middleman’s motion to dismiss Middleman’s motion to dismiss primarily challenges the merits of Crotts’s claims, including by invoking the same res judicata defense that led this Court to dismiss all claims against Freedom Mortgage. See generally Dkt.

47 at 6-21. But as a threshold issue, Middleman disputes the existence of personal jurisdiction, invoking the fiduciary shield doctrine. See id. at 5-6. According to Middleman, the acts and omissions of Freedom Mortgage detailed in the live petition do not provide a basis for exercising jurisdiction over him.

See id. at 6. Crotts responds that Freedom Mortgage is “merely an extension of” Middleman such that that two are alter egos. See Dkt. 51 at 2-3. Middleman is correct that this Court lacks personal jurisdiction over him. For that reason, the Court need not (and should not) reach the merits of

Crotts’s claims. The proper result is to dismiss all remaining claims without prejudice. A. Legal standard: Personal jurisdiction Motions to dismiss for lack of personal jurisdiction are governed by Rule

12(b)(2) of the Federal Rules of Civil Procedure, not Rule 12(b)(6), which Middleman mistakenly cites. When confronted with a personal jurisdiction challenge, “the plaintiff bears the burden to identify facts that demonstrate a prima facie case of jurisdiction.” Bulkley & Assocs., L.L.C. v. Dep’t of Indus.

Relations, 1 F.4th 346, 350 (5th Cir. 2021); see also Herman v. Cataphora, Inc., 730 F.3d 460, 464 (5th Cir. 2013). Absent an evidentiary hearing, the court “must accept the plaintiff’s ‘uncontroverted allegations, and resolve in [the plaintiff’s] favor all conflicts between the facts contained in the parties’

affidavits and other documentation.’” Monkton Ins. Servs., Ltd. v. Ritter, 768 F.3d 429, 431 (5th Cir. 2014) (quoting Revell v. Lidov, 317 F.3d 467, 469 (5th Cir. 2002)). But “the prima-facie-case requirement does not require the court to credit conclusory allegations, even if uncontroverted.” Panda Brandywine

Corp. v. Potomac Elec. Power Co., 253 F.3d 865, 869 (5th Cir. 2001). In a diversity suit, a federal court can exercise personal jurisdiction over a nonresident defendant only to the extent authorized by the forum state’s laws and consistent with federal due process. See Command-Aire Corp. v. Ont.

Mech. Sales & Serv., Inc., 963 F.2d 90, 93 (5th Cir. 1992). “Because the Texas long-arm statute extends to the limits of federal due process, the two-step inquiry collapses into one federal due process analysis.” Sangha v. Navig8 ShipManagement Private Ltd., 882 F.3d 96, 101 (5th Cir. 2018) (citation omitted). “Due process requires that the defendant have minimum contacts

with the forum state (i.e. that the defendant has purposely availed himself of the privilege of conducting activities within the forum state) and that exercising jurisdiction is consistent with traditional notions of fair play and substantial justice.” Id. (quotation omitted).

B. The fiduciary shield doctrine applies. Middleman maintains that Crotts has not demonstrated that Middleman had any personal contacts with Texas that could establish personal jurisdiction here. See Dkt. 47 at 6. According to Middleman, Crotts’s reliance

on the acts and omissions of Freedom Mortgage with respect to the underlying mortgage implicates the fiduciary shield doctrine. See id. at 5-6. In general, “jurisdiction over an individual cannot be predicated upon jurisdiction over a corporation.” Stuart v. Spademan, 772 F.2d 1185, 1197 n.11

(5th Cir. 1985). The fiduciary shield doctrine provides that “an individual’s transaction of business within the state solely as a corporate officer does not create personal jurisdiction over that individual though the state has in personam jurisdiction over the corporation.” Id. at 1197.

As a noted exception, the fiduciary shield doctrine does not apply if the defendant individual is being sued for his own tortious conduct directed at the forum state. See Gen. Retail Servs., Inc. v. Wireless Toyz Franchise, LLC, 255 F. App’x 775, 794-95 (5th Cir. 2007) (discussing Donovan v.

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

Crotts v. Freedom Mortgage Corporation, (S.D. Tex. 2025).

Crotts v. Freedom Mortgage Corporation (Crotts v. Freedom Mortgage Corporation) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related