Garza v. Barella

District Court, S.D. Georgia·Decided April 18, 2025·No. 4:24-cv-00264·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION RAFAEL GARZA, IV, ) ) Plaintiff, ) ) v. ) CV424-264 ) CORY MICHAEL BARELLA, et al., ) ) Defendants. ) ORDER AND REPORT AND RECOMMENDATION Pro se plaintiff Rafael Garza, IV filed this case alleging that his constitutional rights were violated during a traffic stop and subsequent prosecution. See generally doc. 1. He paid the required filing fee and obtained summonses. See, e.g., doc. 3. Defendants Ballard, Barella, Lanier, and Brinson moved to dismiss Garza’s Complaint because he had failed to effectively serve them. See doc. 7. After concluding that, under applicable Eleventh Circuit authority, Garza was entitled to additional time to effect service, the Court dismissed that Motion, without prejudice, and directed Garza to serve the Defendants. See doc. 23. There is no indication that Garza obtained additional summonses, but he did file an

Amended Complaint. Doc. 24. Defendants have moved to dismiss both the original Complaint and the Amended Complaint. Docs. 26 & 27. Garza has responded to the Motions. Doc. 28. Those Motions are, therefore, ripe for review.

The Court must first establish the status of Garza’s Amended Complaint. Defendant’s Motion points out that it could not be filed as a matter of course, pursuant to Federal Rule 15(a)(1), because it was filed

more than twenty-one days after their original Motion to Dismiss. See doc. 27 at 2. Garza’s response does not dispute the Defendants’

argument. See doc. 28 at 1. To the extent that he addresses the substance of the amendment at all, he explains that it was motivated by the District Judge’s admonition that he could not invoke criminal

statutes. See id. However, despite that admonition, the District Judge’s Order does not suggest any direction to or sua sponte leave to amend. See generally doc. 23.

The Eleventh Circuit, following a prominent treatise, has explained: In general, if an amendment that cannot be made as of right is served without obtaining the court’s leave or the opposing party’s consent, it is without legal effect and any new matter it contains will not be considered unless the amendment is resubmitted for the court’s approval. However, some courts have held that an untimely amended pleading served without judicial permission may be considered properly introduced when leave to amend would have been granted had it been sought and when it does not appear that any of the parties will be prejudiced by allowing the change. Permitting an amendment without formal application to the court under these circumstances is in keeping with the overall liberal amendment policy of rule 15(a) and the general desirability of minimizing needless formalities.

Hoover v. Blue Cross & Blue Shield of Ala., 855 F.2d 1538, 1544 (11th Cir. 1988) (quoting 6 Fed. Practice & Procedure § 1485 at 421 (1971)) (emphasis omitted). Even where amendments are not proper as a matter of course, the Federal Rules require that courts “freely give leave [to amend] when justice so requires.” Fed. R. Civ. P. 15(a)(2). As the Supreme Court has explained, “[i]n the absence of any apparent or declared reason—such as undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments

previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of amendment, etc.—the leave sought should, as the rules require, be ‘freely given.’” Foman v. Davis,

371 U.S. 178, 182 (1962). A brief review of the Amended Complaint does not reveal any substantial difference from the Complaint. Compare doc. 1, with doc. 24.

Moreover, as explained below, Garza’s failure to comply with the District Judge’s direction to serve the Defendants mandates dismissal of the Amended Complaint, regardless. It appears that there is no reason why the Court would have denied leave to amend, had Garza sought it. The

Court, therefore, GRANTS Garza leave to amend his Complaint and considers the Amended Complaint the operative pleading in this case. As such, Defendant’s Motion to Dismiss the original Complaint is

DISMISSED as moot. Doc. 26; Auto-Owners Ins. Co. v. Tabby Place Homeowners Ass’n, Inc., 637 F. Supp. 3d 1342, 1348 n. 4 (S.D. Ga. 2022).

Defendants’ Motion to Dismiss the Amended Complaint explains that Garza has failed to effect service as required by the District Judge’s Order. See doc. 27 at 3. The District Judge specifically directed Garza to

serve the Defendants “by no later than twenty-one (21) days from the date of this Order.” Doc. 23 at 4. The Order was entered on March 7, 2025. Given the automatic three-day extension to that deadline provided

by Federal Rule 6(d), Garza was required to effect service by no later than March 31, 2025. See Fed. R. Civ. P. 6(d). There is no indication on the docket that Garza was issued additional summonses to effect service and

his response to the Motion to Dismiss does not assert that he has taken any action to do so. See, e.g., doc. 28 at 1. As the Defendants’ Motion correctly points out, Garza’s filing of the Amended Complaint does not have any effect on service deadlines. See doc. 27 at 3; see also, e.g., Durgin v. Mon, 659 F. Supp. 2d 1240, 1259 (S.D. Fla. 2009) (deadline for service

“is not re-started as to a defendant already named in a prior complaint.”). Garza has, therefore, failed to timely serve any of the Defendants. As the Court previously explained, see doc. 21 at 3-5, before

dismissing an action, without prejudice, where service is not timely effected, the court must consider whether there is “good cause” for the

plaintiff’s failure to timely serve. Lepone-Dempsey v. Carroll Cnty. Comm’rs, 476 F.3d 1277, 1282 (11th Cir. 2007). “Good cause exists only when some outside factor, such as reliance on faulty advice, rather than

inadvertence or negligence, prevented service.” Id. at 1281 (internal quotation marks, alterations, and citation omitted). Even in the absence of such a showing, courts “must still consider whether any other

circumstances warrant an extension of time based on the facts of the case.” Id. at 1282. “Only after considering whether any such factors exist may the district court exercise its discretion and either dismiss the case

without prejudice or direct that service be effected within a specified time.” Id. First, the Court cannot find that Garza has shown good cause for his failure to timely serve Defendants. He does not identify any reason

for his failure, much less an “outside factor,” which prevented him from serving Defendants within the extended deadline provided by the District Judge. “Most courts applying the term ‘good cause’ . . . have found it only

if the plaintiff has been diligent in attempting to serve the complaint.” United States v. Coldwell Banker Bullard Realty Co., Inc., 2009 WL

10664944, at *2 (N.D. Ga. July 22, 2009) (citing Bryant v. Brooklyn Barbecue Corp., 130 F.R.D. 665, 667 (W.D. Mo. 1990)). Given the lack of any showing that he was diligent, the Court finds that Garza has not

shown “good cause” for his failure to timely serve Defendants.

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