Daniels v. Sadeq

CourtDistrict Court, E.D. Michigan
DecidedSeptember 30, 2020
Docket2:20-cv-12671
StatusUnknown

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

Bluebook
Daniels v. Sadeq, (E.D. Mich. 2020).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

MARQUEETA DANIELS CIVIL ACTION NO. 6:20-cv-00783

VERSUS JUDGE JUNEAU

HUSSEIN RIYADH SADEQ, ET AL. MAGISTRATE JUDGE HANNA

REPORT AND RECOMMENDATION

Currently pending are three motions: the motion to dismiss for lack of personal jurisdiction and the motion to dismiss for insufficient service of process, which were filed on behalf of three of the four defendants, namely, Hussein Riyadh Sadeq, Great Lakes Logistics and Transportation, LLC, and Amerisure Mutual Insurance Company (erroneously referred to in the plaintiff’s complaint as Amerisure Insurance Company), and the alternative motion to transfer the action under 18 U.S.C. § 1404(a), which was brought by all four of the defendants, namely, Hussein Riyadh Sadeq, Great Lakes Logistics and Transportation, LLC, Amerisure Mutual Insurance Company, and Great West Casualty Company. (Rec. Doc. 10). Only the motion to dismiss for lack of personal jurisdiction is opposed. The motions were referred to the undersigned magistrate judge for review, report, and recommendation in accordance with the provisions of 28 U.S.C. § 636 and the standing orders of this Court. Considering the evidence, the law, and the arguments of the parties, and for the reasons fully explained below, it is recommended that this action should be transferred to the United States District Court for the Eastern District of Michigan.

Background The plaintiff, Marqueeta Daniels, contends that, on February 12, 2020, she was inside the cab of her 2013 International Prostar truck, which was parked at a

Love’s Truck Stop in Simpson County, Kentucky, when defendant Hussein Riyadh Sadeq, driving a tractor/trailer rig owned by his employer, defendant Great Lakes Logistics and Transportation, LLC, backed his truck into hers. The plaintiff filed suit in Louisiana state court, alleging that she was injured in the collision and that

her truck was damaged. She alleged that Mr. Sadeq was in the course and scope of his employment at the time of the collision, that Great Lakes is vicariously liable for his actions and omissions, and that defendants Amerisure Mutual Insurance

Company and Great West Casualty Company insured Great Lakes, Mr. Sadeq, or both of them. Three of the defendants – Mr. Sadeq, Great Lakes, and Amerisure – removed the action to this forum, with the consent of Great West, alleging that the court has

subject-matter jurisdiction because the parties are diverse in citizenship and the amount in controversy exceeds $75,000. The defendants then filed the instant motions.1 (Rec. Doc. 10).

Law and Analysis Insufficient Service of Process. The defendants argued that Amerisure Mutual Insurance Company was not

properly served because the plaintiff’s petition erroneously referred to and requested service on Amerisure Insurance Company rather than Amerisure Mutual Insurance Company. The defendants further argued that the plaintiff’s error mandates dismissal of her claims against Amerisure Mutual Insurance Company. This Court

notes that the defendants did not set forth the applicable legal standard to be applied when such a motion is considered by the court or indicate that the plaintiff failed to correct the error after having been advised of the insurer’s actual identity.

Federal Rule of Civil Procedure 12(b)(5) provides for dismissal of an action for insufficient service of process. When service of process is challenged, the party

1 In the motion, the defendants stated that Great West was joining only the motion to transfer but not the motion to dismiss for lack of personal jurisdiction or for insufficient service of process. (Rec. Doc. 10 at 1). In the supporting memorandum, however, the defendants stated that “Great Lakes Casualty Company solely is joining in the motion to transfer venue and not the motion to dismiss.” (Rec. Doc. 10-1 at 1, n. 1). No entity called Great Lakes Casualty Company is involved in this litigation. Therefore, this Court assumes that this was a typographical error and that the defendants meant to refer to Great West Casualty Company. While recognizing that Great West joins in only the motion to transfer, this Court will use the shortcut term “the defendants” to refer to the proponents of each motion because it would simply be too cumbersome to repeatedly make the distinction throughout this report and recommendation. responsible for effecting service must bear the burden of establishing its validity.2 Federal Rule of Civil Procedure 4 governs service of process generally, and Rule

4(m) provides: If a defendant is not served within 90 days after the complaint is filed, the court. . . must dismiss the action without prejudice against that defendant or order that service be made within a specified time. But if the plaintiff shows good cause for the failure, the court must extend the time for service.

The burden is on the plaintiff to show good cause as to why service was not effected timely,3 and the plaintiff must demonstrate at least excusable neglect rather than simple inadvertence, a mistake by counsel, or ignorance of the applicable rules.4 Nonetheless, a court has discretion under Rule 4(m) to extend the time for service even in the absence of good cause.5 Obviously, Amerisure Mutual Insurance Company received actual notice of this lawsuit and has appeared herein for certain purposes. The similarity between the name used by the plaintiff in her petition and the name of the entity that actually issued the relevant insurance policy is such that the plaintiff could easily have

2 Aetna Bus. Credit, Inc. v. Universal Décor & Interior Design, 635 F.2d 434, 435 (5th Cir. 1981). 3 McGinnis v. Shalala, 2 F.3d 548, 550 (5th Cir. 1993). 4 Gartin v. Par Pharm. Cos. Inc., 289 Fed. App’x 688, 692 (5th Cir. 2008) (quoting Lambert v. United States, 44 F.3d 296, 299 (5th Cir. 1995)). 5 Thrasher v. City of Amarillo, 709 F.3d 509, 511 (5th Cir. 2013); Millan v. USAA General Indem. Co., 546 F.3d 321, 325 (5th Cir. 2008); Thompson v. Brown, 91 F.3d 20, 21 (5th Cir. 1996). mistaken one for the other. This is the type of situation that should have been addressed in a courteous telephone call to the plaintiff’s counsel rather than in a

written motion that required the expenditure of judicial resources. This Court admonishes the defendants’ counsel to consider, in the future, whether the filing of such a motion is actually necessary or is nothing more than a needless waste of the

court’s time. This Court also notes that the plaintiff did not oppose this motion in its briefing. Nevertheless, this Court will recommend that, in the exercise of the court’s discretion, the plaintiff be afforded an additional thirty days in which to properly serve – or request a waiver of service from – Amerisure Mutual Insurance

Company. Personal jurisdiction. “Federal courts are courts of limited jurisdiction.”6 In order to resolve a case

on the merits, a federal court must have both authority over the type of claim presented in the suit (subject-matter jurisdiction) and authority over the parties (personal jurisdiction).7 In this case, personal jurisdiction is at issue.

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Bluebook (online)
Daniels v. Sadeq, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniels-v-sadeq-mied-2020.