DUAN v. M X PAN INCORPORATED d/b/a FORMOSA SEAFOOD BUFFET

District Court, S.D. Indiana·Decided September 2, 2025·No. 1:22-cv-02333·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

KUN DUAN, ) ) Plaintiff, ) ) v. ) No. 1:22-cv-02333-RLY-KMB ) MX PAN INCORPORATED d/b/a FORMOSA ) SEAFOOD BUFFET, et al., ) ) Defendants. )

ORDER Since May 2023, Defendant Siu Wong Ping a/k/a Suiwong Ping a/k/a Peter Pan ("Mr. Ping") has been representing himself pro se in this case. In October 2024, Mr. Ping appeared ill at an in-person hearing before the undersigned. [Dkt. 62.] The Court took a recess, during which time Mr. Ping's condition worsened and he was ultimately transported to a local hospital and the hearing was adjourned. [Id.] The Court held another hearing six weeks later. Mr. Ping appeared at that hearing in a wheelchair accompanied by his daughter, who informed the Court that her father had suffered a stroke and was not able to speak coherently. [Dkt. 68 at 1.] On January 30, 2025, the undersigned issued a Report and Recommendation on various pending motions in this action. [Dkt. 75.] Among other things, the undersigned recommended "that all proceedings against Defendant Ping be stayed until he is ruled competent or until a guardian ad litem is appointed as his legal representative." [Dkt. 75 at 15.] No Party objected, and the District Judge adopted the undersigned's Report and Recommendation in full. [Dkt. 76.] Thus, this lawsuit as to Defendant Ping only is currently stayed. [Id.] The Court held a competency hearing on July 14, 2025. [Dkt. 94.] Defendant Ping was required to appear in person. All other Parties were invited to the hearing but not required to attend. Defendant Dong, who is Defendant Ping's wife, attended the hearing with him. Plaintiff's counsel did not attend the hearing. The purpose of the hearing was to determine whether Defendant Ping is competent to represent himself in this case. Mr. Ping only speaks Mandarin, so the Court provided a translator for purposes of this hearing. [Id.] The Court asked Mr. Ping a

series of questions. [Id.] Both Mr. Ping and Ms. Dong were given opportunities to speak on their own behalf and ask questions. [Id. at 1-2.] Additional details from the hearing will be discussed more fully herein. I. APPLICABLE STANDARD Federal Rule of Civil Procedure 17(c)(2) states that "the court must appoint a guardian ad litem—or issue another appropriate order—to protect a[n] . . . incompetent person who is unrepresented in an action." Before the court can appoint a guardian ad litem or issue another

appropriate order under this provision, there must be a determination of incompetency. The Seventh Circuit Court of Appeals has described legal competency as a "threshold issue" that must be resolved before adjudicating other aspects of the lawsuit. See Yoder v. Patla, 2000 WL 1225476, at *2 (7th Cir. 2000) (addressing competency before venue issue) (citing T.W. and M.S. by Enk v. Brophy, 124 F.3d 893, 898 (7th Cir. 1997)). Courts must assess a litigant's competency when a party moves for the appointment of a guardian ad litem or raise the issue sua sponte when there is verifiable evidence of incompetency. See U.S. v. 30.64 Acres of Land, More or Less, Situated in Klickitat County, State of Wash., 795 F.2d 796, 805 (9th Cir. 1986) (report from the Social Security Administration that defendant in a lawsuit was mentally disabled required the court to assess his

competency sua sponte); Yoder, 2000 WL 1225476, at *2 (motion claiming that an Illinois county had declared the plaintiff legally disabled "should have apprised the district court of [his condition]" and triggered competency proceedings). Competency can pair with other issues to warrant the appointment of a guardian ad litem or other appropriate order. K.E.SL. v. Anderson, 2015 WL 1275314, at *1 (E.D. Wis. Mar. 19, 2015) ("Because of his age, inability to speak English, and concerns over his competency, the Court appointed an attorney to act as Plaintiff's guardian ad litem.").

If an individual is found to be incompetent, the Court "must appoint a guardian ad litem— or issue another appropriate order" to provide adequate protection for the incompetent individual. Courts have held that appointment of counsel is an example of "another appropriate order" under the rule. See, e.g., Krain v. Smallwood, 880 F.2d 1119, 1121 (9th Cir. 1989) ("Or the court may find that the incompetent person's interests would be adequately protected by the appointment of a lawyer.") A court has a duty to raise the issue of competency sua sponte if it is not raised by the parties. See, e.g., Yoder, 2000 WL 1225476, at *2. The Court has wide discretion in setting a competency hearing, "provided at a minimum the person whose competence is in question receives notice and an opportunity to be heard." Steven Gensler, 1 Federal Rules of Civil Procedure, Rules

and Commentary Rule 17 (February 2024) (citing Sturdza v. United Arab Emirates, 562 F.3d 1186, 1189 (D.C. Cir. 2009)); see also Thomas v. Humfield, 916 F.2d 1032, 1034 (5th Cir. 1990). "The opportunity to be heard must be tailored to the capacities and circumstances of those who are to be heard." Goldberg v. Kelly, 397 U.S. 254, 268-69 (1970). But the fact that the Court holds a hearing on competency does not require the Court to find the individual is incompetent. Zolnierz v. Arpaio, 2013 WL 253870, at *1 (D. Ariz. Jan. 23, 2013). "Individuals are incompetent for Rule 17 purposes only if they lack the capacity to litigate under the law of their domicile." Burress v. Blake, 2016 WL 11475017, at *1 (E.D. Tex. Oct. 12, 2016). See also Yoder, 2000 WL 1225476, at *3 ("Under Rule 17(c) . . . mental competency is determined by reference to the law of the party's domiciliary state." ). II. DISCUSSION A. Competency Determination

Mr. Ping is domiciled in Indiana. He owns a home in Indiana, [dkt. 67 at 4], recently operated an Indiana business, [dkt. 1 at 2-3], has regular medical appointments in Indiana, [dkt. 96 at 9, 11], and has a service address in Indiana for purposes of this lawsuit. Accordingly, the Court will apply relevant provisions of Indiana law in evaluating Mr. Ping’s competency. "Indiana courts have rarely had occasion to interpret [Indiana] Trial Rule 17(c) as it applies to incompetent persons." Ramos v. Robertson's Apts., 2012 WL 5818306, at *2 (Ind. Ct. App. 2012). However, Indiana courts have relied on the "federal and state counterparts" and concluded that "Trial Rule 17(c) gives the trial court discretion to determine whether an incompetent person is adequately represented in the proceedings such that no guardian ad litem is necessary." Id. (citing Brewer v. Brewer, 403 N.E.2d 352, 354 (Ind. Ct. App. 1980)). Indiana courts have also

used a broad interpretation of competency in line with the purpose of the Rule: the trial court should act when the "party litigant is not competent, understandingly and intelligently, to comprehend the significance of legal proceedings and the effect and relationship of such proceedings in terms of the best interests of such party litigant." Id. (quoting 53 Am. Jur. 2d Mentally Impaired Persons § 162 (2012)). The Court will consider Mr.

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DUAN v. M X PAN INCORPORATED d/b/a FORMOSA SEAFOOD BUFFET, (S.D. Ind. 2025).

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