Davidson v. Rand, et al.

2005 DNH 060
CourtDistrict Court, D. New Hampshire
DecidedApril 6, 2005
Docket05-CV-012-SM
StatusPublished

This text of 2005 DNH 060 (Davidson v. Rand, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Davidson v. Rand, et al., 2005 DNH 060 (D.N.H. 2005).

Opinion

Davidson v . Rand, et a l . 05-CV-012-SM 04/06/05 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

L . John Davidson, Plaintiff

v. Civil N o . 05-cv-012-SM Opinion N o . 2005 DNH 060 James H . Rand, Arthur Blasberg, Jr., John Beinecke, Eugene D. Brody, Daniel E . Best, William L . Gorman, Armand O . Norehad, Antaeus Enterprises, Inc. and Atlantic Capital Partners, LLC., Defendants

O R D E R

In September of 2004, L . John Davidson filed a writ of

summons in the Rockingham County (New Hampshire) Superior Court,

setting forth five claims against nine defendants. Subsequently,

one of those defendants, Armand Norehad, removed the action,

invoking this court’s diversity jurisdiction. Davidson now moves

the court to remand the action to state court. Defendants

object. For the reasons set forth below, Davidson’s motion to

remand is granted. Legal Standard

Title 28 U.S.C. § 1446, the federal statute governing

removal of actions from state court, provides, in pertinent part,

that:

The notice of removal of a civil action or proceeding shall be filed within thirty 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, or within thirty days after the service of summons upon the defendant if such initial pleading has then been filed in court and is not required to be served on the defendant, whichever period is shorter.

28 U.S.C. §1446(b). See also 28 U.S.C. § 1441 (describing the

circumstances under which an action originally filed in state

court may be removed to federal court). “In cases involving

multiple defendants, all defendants who have been served must

join or assent in the removal petition.” Swanston v . TAP Pharm.

Prods., 307 F. Supp. 2d 1 9 0 , 193 (D. Mass. 2004) (citing Lapides

v . Bd. of Regents, 535 U.S. 613, 620 (2002)). When removal is

challenged, the removing party bears the burden of demonstrating

that the asserted basis for removal satisfies the statutory

requirements. Sirois v . Business Express, Inc., 906 F. Supp.

722, 725 (D.N.H. 1995).

2 Discussion

Davidson commenced this action in state court on September

1 7 , 2004. By November 5th, all but one defendant had been served

(the “First-Served Defendants”). None of the First-Served

Defendants exercised its right to remove the case within the

statutorily prescribed 30-day period. Subsequently, Davidson

effected service upon the final defendant, Armand Norehad.

Within the period allowed by section 1446, Norehad removed the

state court action to this court. All other defendants consented

(though Davidson’s motion to remand challenges those defendants’

ability to “consent,” given that their right to remove had

already lapsed).

There appears to be no dispute that, pursuant to 28 U.S.C. §

1332, this court has subject matter jurisdiction over Davidson’s

claims. Nor do the parties dispute that Norehad removed this

action within 30 days of his having been served, as required by

section 1446(b). The sole question presented by Davidson’s

motion to remand is whether Norehad could remove the action after

the First-Served Defendants’ time for doing so had lapsed. Or,

viewed somewhat differently, the question is whether the First-

3 Served Defendants had the capacity to consent to Norehad’s

removal after failing to exercise their own right to remove in a

timely manner.

There is a growing split of opinion on the issue presented,

even within this circuit, and even among judges within individual

districts of this circuit. Compare Karpowicz v . Blue Cross &

Blue Shield of Mass., 1996 WL 528372 (D. Mass. Aug. 1 9 , 1996)

with Garside v . Osco Drug, Inc., 702 F. Supp. 19 (D. Mass. 1988).

See generally 14C Charles Alan Wright & Arthur R. Miller, Federal

Practice and Procedure, § 3732 at 336-40 n.74 and 75 (2004 Supp.)

(collecting numerous cases on both sides of this issue). The

majority of courts that have confronted the issue have concluded

that once a defendant’s right to remove a proceeding has lapsed,

that defendant cannot consent to subsequent removal efforts

undertaken by a later-served defendant. This has become known as

the “first-served defendant” rule or the “rule of unanimity.”

Prior to his elevation to the Court of Appeals for the First

Circuit, Judge Selya embraced the rule of unanimity and,

addressing the point in detail, concluded:

4 In the typical scenario, a plaintiff sues multiple defendants, who are served in random sequence. A defendant which is served toward the end of this temporal daisy chain seeks to remove the action: that defendant acts within thirty days of its receipt of the initial pleading, but after earlier-served defendants have let their respective thirty day periods run without incident. . . . In such a situation, courts have been consentient in holding that, even if the movant secures the acquiescence of the earlier-served defendants in the removal initiative, the petition must, upon timely objection by the plaintiff, be denied.

The reasoning of these courts is impeccable. The right to remove is of finite duration; if not activated promptly, it self-destructs. Once Humpty-Dumpty has toppled from the wall, he cannot be put back together again. Failure of a defendant to embark upon removal within the statutorily allotted time causes the right to perish. Such neglect cannot be cured retroactively by joining a subsequently-served defendant’s removal pavane. The first defendant having irretrievably lost the facility to effectively remove, it has likewise lost the facility effectively to consent to any other defendant’s attempt to remove the action. That being s o , and all defendants being required to join in a proper removal petition in a diversity case, the first- served defendant’s debarment vitiates the (timely) application of the later-served defendant.

Gorman v . Abbott Laboratories, 629 F. Supp. 1196, 1201 (D.R.I.

1986) (emphasis supplied) (citations omitted). See also Hill v .

Phillips, Barratt, Kaiser Eng’g Ltd., 586 F. Supp. 944 (D. M e .

1984) (prior to his elevation to the circuit court of appeals,

then Chief District Court Judge Cyr concluded that once a

5 defendant failed to file a removal petition within 30 days of

service, it no longer had the capacity to consent to a later-

served defendant’s removal efforts). Applying the reasoning of

Judges Selya and Cyr, this court previously adopted the rule of

unanimity. See Sager v . Wante, N o . 95-524-M (D.N.H. Nov. 3 0 ,

1995) (McAuliffe, J . ) .

Recently, however, some courts have begun to rethink the

issue and embrace the so-called “fairness approach,” which

affords every defendant 30 days within which to exercise its

right to remove, and allows the remaining defendants to consent

to that removal, even if their own right to remove has lapsed.

See, e.g., Garside, 702 F. Supp. at 22 (D. Mass. 1988) (“a

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Related

Maguire v. Commissioner
313 U.S. 1 (Supreme Court, 1941)
Lapides v. Board of Regents of Univ. System of Ga.
535 U.S. 613 (Supreme Court, 2002)
Gorman v. Abbott Laboratories
629 F. Supp. 1196 (D. Rhode Island, 1986)
Sirois v. Business Express, Inc.
906 F. Supp. 722 (D. New Hampshire, 1995)
Garside Ex Rel. Garside v. Osco Drug, Inc.
702 F. Supp. 19 (D. Massachusetts, 1988)
Lawton v. Republic of Iraq
307 F. Supp. 2d 1 (District of Columbia, 2004)
U.S. Express Lines, Ltd. v. Higgins
281 F.3d 383 (Third Circuit, 2002)

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