Drum Lodge, LLC v. Martel Construction, Inc.

CourtDistrict Court, E.D. California
DecidedApril 4, 2024
Docket2:24-cv-00219
StatusUnknown

This text of Drum Lodge, LLC v. Martel Construction, Inc. (Drum Lodge, LLC v. Martel Construction, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Drum Lodge, LLC v. Martel Construction, Inc., (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 ----oo0oo---- 11 12 DRUM LODGE, LLC, No. 2:24-cv-00219 WBS JDP 13 Plaintiff, 14 v. ORDER 15 MARTEL CONSTRUCTION, INC., 16 Defendant. 17 18 ----oo0oo---- 19 Congress passed the Federal Arbitration Act, 9 U.S.C. 20 ch. 1, in 1925, observing that “action should be taken at this 21 time when there is so much agitation against the costliness and 22 delays of litigation . . . these matters can be largely 23 eliminated by agreements for arbitration. . . .” H.R. Rep. No. 24 68-96, at 2 (1924). 25 Alas. What started here as a simple dispute about a 26 contract has morphed into this convoluted dispute about 27 arbitration. After the parties agreed to submit their dispute to 28 arbitration, plaintiff, unhappy with the arbitrators’ decision in 1 favor of defendant, has petitioned this court to vacate the 2 award. (Pet. (Docket No. 1); Mot. to Vacate (Docket No. 8).) 3 The matter is now before the court on defendant’s motion to 4 dismiss the petition. (Mot. to Dismiss (Docket No. 12-1).)1 So 5 much for eliminating the agitation, costliness and delay of 6 litigation. 7 As the parties are familiar with the factual and 8 procedural background, the court proceeds directly to the 9 parties’ arguments. 10 I. Timely Service (Rule 12(b)(5)) 11 As a threshold matter, defendant argues that plaintiff 12 failed to effect proper service pursuant to Federal Rules of 13 Civil Procedure 12(b)(5) and 4(h), thereby creating a 14 jurisdictional bar for the court to consider plaintiff’s 15 petition. (See Mot. to Dismiss at 13-21.) Specifically, 16 defendant argues that plaintiff’s ultimate service upon Rachel 17 Buchner and Keeley Davisworth was defective service. In support, 18 defendant relies on Rule 4(h)(1)(A), which states in relevant 19 part that a foreign corporation must be served in the manner 20 prescribed by Rule 4(e)(1) for serving an individual. See Fed. 21 R. Civ. P. 4(h)(1)(A). (See Mot. to Dismiss at 16-17.) Rule 22 4(e)(1) in turn states in relevant part that an individual may be 23 served by “following state law for serving a summons in an action 24 brought in courts of general jurisdiction in the state where the 25 district court is located or where service is made.” Fed. R. 26 1 Meanwhile, defendant has filed a separate petition in a 27 separate court to confirm the same arbitration award. (See Docket No. 12-2 Ex. 3.) Apparently, however, that petition is 28 beyond this court’s current purview. 1 Civ. P. 4(e)(1). Defendant accordingly argues that under Montana 2 law regarding service, which Montana courts construe strictly, 3 neither Ms. Buchner nor Ms. Davisworth belong in the category of 4 persons empowered to accept service. See Mont. R. Civ. P. 5 4(i)(3). (See Reply (Docket No. 18) at 14 (citing In re Marriage 6 of Zacher, 98 P.3d 309, ¶¶ 16-17 (Mont. 2004).) 7 Here, however, Rule 4(e)(1) also permits service 8 according to California state law. See Fed. R. Civ. P. 4(e)(1) 9 (allowing service pursuant to law “in the state where the 10 district court is located . . . .”).2 Unlike Montana law, 11 California law does not require strict compliance with service 12 requirements. See Ramos v. Homeward Residential, Inc., 223 13 Cal.App.4th 1434, 1442-43 (Cal. App. 4th Dist. 2014) (“It is 14 axiomatic that strict compliance with the [California] code's 15 provisions for service of process is not required. [. . .] 16 [S]ubstantial compliance with the code occurs when, although not 17 properly identified in a proof of service, the person to be 18 served in fact actually received the summons.”).3 4

19 2 See also 1 Moore's Federal Practice - Civil § 4.90 (“If . . . the individual is to be served in some other state [than 20 the forum state], process may be served under either the law of 21 the state where service is made or the law of the forum state.”). 22 3 See also Days Inns Worldwide, Inc. v. Patel, 445 F.3d 899, 904 (6th Cir. 2006) (service was effective when it 23 substantially complied with state statute, even though summons was mailed by attorney rather than by court clerk as required by 24 statute); Nikwei v. Ross Sch. of Aviation, Inc., 822 F.2d 939, 943–945 (10th Cir. 1987) (although summons was mailed without 25 request for return receipt, defendant’s refusal to accept service 26 by certified mail warranted granting of default judgment for plaintiff). 27 4 This also accords with the federal rule in this circuit 28 that “[s]o long as a party receives sufficient notice of the 1 Defendant does not argue that it did not have actual 2 notice or that it would be prejudiced by maintaining the action 3 notwithstanding allegedly defective service. Further, plaintiff 4 demonstrates that its process server tried several times to 5 personally serve Mr. Tony Martel, defendant’s president and chair 6 of its board, at his home and at defendant’s place of business. 7 (Docket No. 17-4.) The record shows similar repeated efforts to 8 physically serve defendant’s counsel. (Id.) Finally, defendant 9 notes that plaintiff “cannot timely effectuate service on 10 [defendant] within the FAA’s three-month deadline [to move to 11 vacate a final award].”5 (Mot. to Dismiss at 19-20.) This is 12 clear indication that plaintiff would be severely prejudiced if 13 its petition were dismissed, even if given leave to re-attempt 14 service. The court therefore concludes that plaintiff has 15 effected substantially satisfactory service. 16 Accordingly, the court will not dismiss plaintiff’s 17 petition for failure to properly serve defendant.6 18 II. Subject Matter Jurisdiction (Rule 12(b)(1)) 19 Next, defendant argues that this court lacks subject 20 complaint, Rule 4 is to be ‘liberally construed’ to uphold 21 service.” Travelers Cas. & Sur. Co. of Am. v. Brenneke, 551 F.3d 1132, 1135 (9th Cir. 2009) (quoting Chan v. Soc'y Expeditions, 22 Inc., 39 F.3d 1398, 1404 (9th Cir. 1994)). 23 5 The final award was issued and delivered on October 25, 2023. The deadline to move to vacate was January 25, 2024. (See 24 Mot. to Dismiss at 20.) 25 6 In its opposition, plaintiff also requests costs 26 associated with service as a sanction for defendant’s purported “evasion of service.” (Opp’n (Docket No. 17) at 17.) The court 27 declines to do so, as the record does not show any behavior anywhere near egregious enough to merit sanctions. 28 1 matter jurisdiction over plaintiff’s petition pursuant to Federal 2 Rule of Civil Procedure 12(b)(1). 3 The court disagrees. The court plainly has diversity 4 jurisdiction because the parties are diverse and the amount in 5 controversy exceeds $75,000.7 See 28 U.S.C. § 1332. (See Pet. ¶ 6 3.) See also Badgerow v. Walters, 596 U.S. 1, 9 (2022) (“The 7 issue here is about where a federal court should look to 8 determine whether an action brought under [FAA] Section 9 or 10 9 has an independent jurisdictional basis. An obvious place is the 10 face of the application itself. If it shows that the contending 11 parties are citizens of different States (with over $75,000 in 12 dispute), then § 1332(a) gives the court diversity 13 jurisdiction.”). None of defendant’s arguments identify any 14 15 7 The final award exceeds $2 million. (Docket No.

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