Franklin v. Access Corrections

CourtNew Mexico Court of Appeals
DecidedAugust 11, 2025
DocketA-1-CA-41658
StatusUnpublished

This text of Franklin v. Access Corrections (Franklin v. Access Corrections) is published on Counsel Stack Legal Research, covering New Mexico Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Franklin v. Access Corrections, (N.M. Ct. App. 2025).

Opinion

This decision of the New Mexico Court of Appeals was not selected for publication in the New Mexico Appellate Reports. Refer to Rule 12-405 NMRA for restrictions on the citation of unpublished decisions. Electronic decisions may contain computer- generated errors or other deviations from the official version filed by the Court of Appeals.

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

No. A-1-CA-41658

BRYCE FRANKLIN,

Plaintiff-Appellant,

v.

ACCESS CORRECTIONS,

Defendant-Appellee.

APPEAL FROM THE DISTRICT COURT OF DOÑA ANA COUNTY James T. Martin, District Court Judge

Bryce Franklin Santa Fe, NM

Pro Se Appellant

Spencer Fane, LLP Scott Woody Santa Fe, NM

for Appellee

MEMORANDUM OPINION

WRAY, Judge.

{1} The district court dismissed Plaintiff’s complaint against Defendant, Access Corrections, without prejudice for insufficient service. On appeal, we conclude that Plaintiff did not satisfy the requirements of Rule 1-004 NMRA for the proper service of a business entity by mail and that the district court did not abuse its discretion by concluding that Plaintiff did not act with reasonable diligence under the circumstances. We therefore affirm.

DISCUSSION {2} Because this is a memorandum opinion, we reserve factual discussion for that necessary to explain our analysis. On appeal, the parties dispute whether Plaintiff satisfied the requirements for proper service under Rule 1-004(E) and Rule 1-004(G), and whether, regardless, Plaintiff acted with reasonable diligence to serve Defendant under Rule 1-004(C)(2). In these circumstances, we are “deferential to the facts found by the [district] court, but review[] conclusions of law de novo.” See Edmonds v. Martinez, 2009-NMCA-072, ¶ 8, 146 N.M. 753, 215 P.3d 62. “A district court’s determination that a plaintiff failed to act with reasonable diligence under Rule 1- 004(C)(2), and whether the complaint should be dismissed as a result, is reviewed only for abuse of discretion.” Murphy v. Lash, 2024-NMCA-031, ¶ 18, 545 P.3d 1169. We begin with the provisions of Rule 1-004 before turning to the parties’ specific arguments.

{3} Rule 1-004(E) is titled, “Process; how served; generally.” Initially, Rule 1- 004(E)(1) directs that “[p]rocess shall be served in a manner reasonably calculated, under all the circumstances, to apprise the defendant of the existence and pendency of the action and to afford a reasonable opportunity to appear and defend.” Next, the rule addresses the relationship between the service methods identified in the rule and any applicable statute. Rule 1-004(E)(2). Last, Rule 1-004(E)(3) explains:

Service may be made by mail or commercial courier service provided that the envelope is addressed to the named defendant and further provided that the defendant or a person authorized by appointment, by law or by this rule to accept service of process upon the defendant signs a receipt for the envelope or package containing the summons and complaint, writ or other process. Service by mail or commercial courier service shall be complete on the date the receipt is signed as provided by this subparagraph. For purposes of this rule “signs” includes the electronic representation of a signature.

We refer to the service described in Rule 1-004(E)(3) as mail service. Thus, generally under Rule 1-004(E), mail service may be made on the defendant or a person authorized to accept service if one of those persons signs a receipt for the service.

{4} For its part, Rule 1-004(G) is titled, “Process; service on a corporation or other business entity.” For identified business entities, in relevant part, under Rule 1- 004(G)(1)(a), service may be made on an officer, managing or general agent, or any other agent authorized by appointment. Under Rule 1-004(G)(2), again in relevant part,

[i]f a person described in Subparagraph (a) . . . of this subparagraph refuses to accept the process, tendering service as provided in this paragraph shall constitute valid service. If none of the persons mentioned is available, service may be made by delivering a copy of the process or other papers to be served at the principal office or place of business during regular business hours to the person in charge. According to Rule 1-004(G)(3), mail service under Rule 1-004(E)(3) may be made on the persons identified in Rule 1-004(G)(1).

{5} If service under these or other methods is delayed, the district court may “exercise its discretion in determining whether a delay in service of process demonstrates a lack of due diligence on the part of a plaintiff based on a standard of objective reasonableness.” Graubard v. Balcor Co., 2000-NMCA-032, ¶ 12, 128 N.M. 790, 999 P.3d 434; see Rule 1-004(C)(2) (providing broadly that “[s]ervice of process shall be made with reasonable diligence, and the original summons with proof of service shall be filed with the court in accordance with the provisions of Paragraph L of this rule”). In that inquiry, “[i]f the [district] court determines that a plaintiff failed to exercise due diligence in serving process on a defendant, the court must exercise its discretion to determine whether the delay warrants dismissal of the complaint.” Romero v. Bachicha, 2001-NMCA-048, ¶ 23, 130 N.M. 610, 28 P.3d 1151.

{6} With this legal background, we turn to the arguments that Plaintiff makes to attempt to demonstrate that the district court abused its discretion by dismissing the complaint for insufficient service. Plaintiff, who is a New Mexico state prisoner, maintains that the original service, made in April 2023, was proper because the summons and complaint were mailed to Defendant’s principal place of business pursuant to Rule 1-004(G)(2). Plaintiff also argues that Defendant was properly served a second time when he mailed a copy of the complaint and summons to Defendant’s registered agent in August 2023. Last, Plaintiff contends that regardless of whether service was sufficient, he established that he acted with due diligence under the circumstances to effect service, and dismissal was therefore improper. We address each argument in turn.

{7} Plaintiff’s April 2023 attempt to serve Defendant at its principal place of business did not comply with the conditions in Rule 1-004. Under Rule 1-004(G)(2), “a copy of the process or other papers to be served” may be delivered to “the principal office or place of business.” Plaintiff, however, used Rule 1-004(G)(2) in tandem with the mail service option, and under that rule, service is not “complete” until a person who is authorized to accept service “signs a receipt for the envelope or package.” See Rule 1-004(E)(3). Plaintiff contends that because of a lack of resources and online access, he could not discover Defendant’s registered agent and as a result, the registered agent was “unavailable” for the purposes of Rule 1-004(G)(2). Assuming both that this assertion is factually true and that a person may be “unavailable” for the purposes of Rule 1- 004(G)(2) if a plaintiff is unable to identify them, Plaintiff nevertheless did not respond to Defendant’s motion to dismiss with any allegation or evidence that any receipt was signed by a person authorized to accept service or a “person in charge.” 1 See id. Plaintiff therefore did not show that the April 2023 service was accomplished. See Rule

1It is not clear whether our Supreme Court intended for Rule 1-004(G)(2) and Rule 1-004(E)(3) to combine such that when a person identified in Rule 1-004(G)(1) refuses service and/or is not available, mail service under Rule 1-004(E)(3) on a “person in charge” is permissible under Rule 1-004(G)(2). We need not consider the intent behind the rules further because we conclude that even if combining the rules in this manner is permissible, Plaintiff did not satisfy the requirements. 1-004, comm. cmt.

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Related

Edmonds v. Martinez
2009 NMCA 072 (New Mexico Court of Appeals, 2009)
Graubard v. Balcor Co.
2000 NMCA 032 (New Mexico Court of Appeals, 2000)
Romero v. Bachicha
2001 NMCA 048 (New Mexico Court of Appeals, 2001)
Hale v. Basin Motor Co.
795 P.2d 1006 (New Mexico Supreme Court, 1990)
State v. Ferry
2018 NMSC 4 (New Mexico Supreme Court, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Franklin v. Access Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/franklin-v-access-corrections-nmctapp-2025.