G & C Food Distributors & Brokers Inc. v. Base Carriers, LLC

CourtDistrict Court, N.D. New York
DecidedMarch 21, 2025
Docket5:24-cv-00707
StatusUnknown

This text of G & C Food Distributors & Brokers Inc. v. Base Carriers, LLC (G & C Food Distributors & Brokers Inc. v. Base Carriers, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
G & C Food Distributors & Brokers Inc. v. Base Carriers, LLC, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ______________________________________________________

G & C FOOD DISTRIBUTORS & BROKERS, INC.,

Plaintiff,

v. 5:24-CV-707 (FJS/ML)

BASE CARRIERS, LLC, and LANDL TRUCKING, LLC,

Defendants. _____________________________________________________

APPEARANCES OF COUNSEL

UNDERBERG & KESSLER LLP COLIN D. RAMSEY, ESQ 50 Fountain Plaza, Suite 320 PAUL F. KENEALLY, ESQ. Buffalo, New York 14202 Attorneys for Plaintiff

GOLDBERG SEGALLA LLP ASHLYN M. CAPOTE, ESQ. 665 Main Street JONATHAN SCHAPP, ESQ. Buffalo, New York 14203 Attorneys for Defendant Base Carriers, LLC

HOWARD & HOWARD ATTORNEYS PLLC JONATHAN F. KARMO, ESQ. 450 West 4th Street MILES T. MACIK, ESQ. Royal Oak, Michigan 48067 Attorneys for Defendant Base Carriers, LLC

LANDL TRUCKING LLC NO APPEARANCE

SCULLIN, Senior Judge MEMORANDUM-DECISION AND ORDER I. NTRODUCTION Pending before the Court is Plaintiff's motion to remand this matter to the New York Supreme Court, Onondaga County, New York. See Dkt. No. 18. Defendant Base Carriers, LLC

("Defendant Base Carriers") opposes this motion. See Dkt. No. 25.

II. BACKGROUND Plaintiff alleges that Defendant Base Carriers breached a contract to deliver food products for Plaintiff in Texas. Defendant Base Carriers had subcontracted the delivery to Defendant Landl Trucking, LLC ("Defendant Landl"), but a third-party impersonated Defendant Landl and stole the delivery. No one ever delivered the product, worth more than $500,000, for Plaintiff. Plaintiff also sues Defendant Landl as the intended third-party beneficiary of the subcontract between Defendants Base Carriers and Landl. Plaintiff filed the case in New York Supreme Court, Onondaga County, on April 18,

2024. See Dkt. No. 2. Defendant Base Carriers' attorney signed an acknowledgement of service on April 25, 2024. See id. Plaintiff served Defendant Landl on May 1, 2024. See Dkt. Nos. 2, 9. On May 24, 2024, Defendant Base Carriers removed the case to this Court citing diversity jurisdiction as the basis for removal. See Dkt. No. 1. The Notice of Removal avers that, "[p]ursuant to 28 U.S.C. § 1446(b), as of the date of the filing of this Notice of Removal, all properly served and joined Defendants (Base Carriers) consent[] to removal of this action to this Court." See id. at ¶ 14. Although the Notice of Removal does not mention Defendant Landl, it contains a copy of the proof of service for [Defendant] Landl. See Dkt No. 1-1 at 9. Defendant Base Carriers filed a motion to dismiss for lack of subject matter jurisdiction. See Dkt. No. 6. Plaintiff then filed the instant motion. See Dkt. No. 18. The Court granted Plaintiff's letter request to stay the briefing on the motion to dismiss until the Court addressed the motion to remand. See Dkt. No. 20.

III. DISCUSSION A. Legal Standard "The removal statute provides that 'all defendants who have been properly joined and served must join in or consent to the removal of the action,' and that the 'notice of removal of a civil action or proceeding shall be filed within 30 days' of the defendant receiving the initial pleading or the summons." Taylor v. Medtronic, Inc., 15 F.4th 148, 149 (2d Cir. 2021) (quoting 28 U.S.C. § 1446(b)(1)-(2)(B)). "A notice of removal must be signed by at least one attorney of record in accordance with Rule 11; contain a short and plain statement of the basis for removal; and include a copy of all process, pleadings, and orders served upon the defendants in the

action." Id. at 150 (citing [28 U.S.C.] § 1446(a), (b)). Courts refer to the requirement that all properly served and joined defendants join in the removal notice as the "rule of unanimity." Id. This rule serves the interests of all parties and the courts because "it benefits plaintiffs by preventing defendants from splitting the litigation, forcing the plaintiff to pursue the case in two separate forums. It benefits defendants by precluding one defendant from imposing its forum choice on codefendants. And it helps courts by preventing needless duplication of litigation."

Id. (quoting 16 Moore's Federal Practice -- Civil § 107.42 (2018)). Moreover, "'statutory procedures for removal are to be strictly construed,'" and courts "'resolv[e] any doubts against removability.'" Id. (quoting In re Methyl Tertiary Butyl Ether Prods. Liab. Litig., 488 F.3d 112, 124 (2d Cir. 2007) (internal quotation marks and citation omitted, alteration in original)) (other citations omitted). "It is" also "well-established that defendants 'must independently express their consent to removal.'" Id. at 151 (quoting Pietrangelo v. Alvas Corp., 686 F.3d 62, 66 (2d Cir. 2012)).

B. Analysis Plaintiff seeks remand because, although the Notice of Removal makes clear that Defendant Landl was served before Defendant Base Carriers filed the Notice, Defendant Landl's consent to removal is not contained with the Notice. This defect, Plaintiff claims, makes the notice of removal improper and mandates remand. Defendant Base Carriers does not deny that Defendant Landl did not consent to the removal. Instead, Defendant Base Carriers argues that Defendant Landl was not properly joined; and, therefore, the rule of unanimity does not apply and does not bar removal without Defendant Landl's consent. Indeed, Defendant Base Carriers argues that Plaintiff sued an improper party.

Plaintiff entered into a contract with Base Carriers Services, LLC, not the named Defendant "Base Carriers, LLC". Similarly, no subcontract between Defendant Landl and Defendant Base Carriers, LLC exists. The subcontract in question was between Base Carriers Services, LLC and Defendant Landl. Thus, Defendant Base Carriers claims that (1) Plaintiff does not have a colorable claim against Defendant Landl; (2) Defendant Landl was fraudulently joined and (3) the Court should deny Plaintiff's motion to remand. Defendant Base Carriers, however, does not deny that Defendant Landl was a party to the subcontract in question. Furthermore, Defendant Base Carriers admits that the Notice of Removal lacks consent from Defendant Landl. Nonetheless, Defendant Base Carriers argues that remand is unnecessary because Defendant Landl was fraudulently joined in the state-court action. Courts find an exception to the rule of unanimity "for defendants who have not been

served, unknown defendants, and fraudulently joined defendants." Sherman v. A.J. Pegno Constr. Corp., 528 F. Supp. 2d 320, 330 (S.D.N.Y. 2007) (citing Varela v. Flintlock Constr., Inc., 148 F. Supp. 2d 297, 300 (S.D.N.Y. 2001)). "The doctrine of fraudulent joinder is meant to prevent plaintiffs from joining non-diverse parties in an effort to defeat federal jurisdiction." Briarpatch Ltd., L.P. v. Phoenix Pictures, Inc., 373 F.3d 296, 302 (2d Cir. 2004). "Under this doctrine, courts overlook the presence of a non-diverse defendant if from the pleadings there is no possibility that the claims against that defendant could be asserted in state court." Id. (citing Pampillonia v.

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