Gladstone Industries Corporation and Vicki Atlasman v. Fair and Fast Logistics, Inc. and Artisan & Truckers Casualty Company

CourtDistrict Court, D. New Mexico
DecidedNovember 25, 2025
Docket1:25-cv-00665
StatusUnknown

This text of Gladstone Industries Corporation and Vicki Atlasman v. Fair and Fast Logistics, Inc. and Artisan & Truckers Casualty Company (Gladstone Industries Corporation and Vicki Atlasman v. Fair and Fast Logistics, Inc. and Artisan & Truckers Casualty Company) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gladstone Industries Corporation and Vicki Atlasman v. Fair and Fast Logistics, Inc. and Artisan & Truckers Casualty Company, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

GLADSTONE INDUSTRIES CORPORATION and VICKI ATLASMAN,

Plaintiffs,

v. Civ. No. 25-665 SCY/JFR

FAIR AND FAST LOGISTICS, INC. and ARTISAN & TRUCKERS CASUALTY COMPANY,

Defendants.

MEMORANDUM OPINION AND ORDER GRANTING MOTION TO REMAND Plaintiffs move to remand this case to state court, arguing that the procedural requirement that all served defendants consent to removal is not met. Because the non-removing Defendant did not timely provide independent and unambiguous consent to removal, the Court finds the notice of removal procedurally deficient and grants the motion to remand. BACKGROUND Plaintiffs Gladstone Industries Corporation and Vicki Atlasman filed suit in state court against Defendants Fair and Fast Logistics, Inc., Artisan & Truckers Casualty Company, and Pedro Casseus.1 Doc. 1-1. Plaintiffs served Fair and Fast and Artisan & Truckers on June 17, 2025. Docs. 1-2, 1-3. On July 15, 2025, Fair and Fast filed a notice of removal based on diversity jurisdiction, in which it asserted that “Defendant Artisan consents to the removal of this action.”

1 As of July 15, 2025. when the case was removed, Plaintiffs had not served Pedro Casseus. Plaintiffs later filed a First Amended Complaint, which still names Pedro Casseus in the caption, but the body of the complaint makes it clear that Plaintiffs removed him as a defendant in the case. Doc. 8. Doc. 1 at 4. On August 13, Artisan & Truckers appeared in the case and filed a motion to dismiss. Docs. 14, 15. The next day, Plaintiffs timely filed a motion to remand, arguing that Artisan & Truckers did not properly and timely consent to removal. Doc. 17; see also Doc. 22 (response); Doc. 24 (reply). Thereafter, on August 27, 2025, Artisan & Truckers filed a notice of consent to removal. Doc. 23.

DISCUSSION 1. Meet and Confer As an initial matter, Fair and Fast asserts that the Court should summarily deny Plaintiffs’ motion to remand because Plaintiffs did not confer with opposing counsel before filing the motion. Doc. 22 at 2-3. This District’s Local Rules require that a “[m]ovant must determine whether a motion is opposed, and a motion that omits recitation of a good-faith request for concurrence may be summarily denied.” D.N.M. LR-Civ. 7.1(a). Here, although Plaintiffs’ motion contains a statement that “[t]his Motion for Remand is opposed,” Doc. 17 at 1 n.1, Plaintiffs appear to concede that they did not actually confer with Fair and Fast before making

that assertion. See Docs. 22 at 2-3; Doc. 24 at 2. The Court thus admonishes Plaintiffs that Local Rule 7.1(a) applies to all motions and that a movant must actually confer with the other side before making a representation regarding concurrence or opposition. See Sanders v. USAA Cas. Ins. Co., No. 19-CV-0895 KWR/SMV, 2020 WL 486978, at *4 n.3 (D.N.M. Jan. 30, 2020) (“The text of Local Rule 7.1(a) and precedent within the Tenth Circuit clearly require counsel to confer before filing any motion, regardless of what a party may infer.”) (citing D.N.M.LR-Civ. 7.1(a); Hooten v. Ikard Servi Gas, 525 F. App’x 663, 667 (10th Cir. 2013); Ortega v. N.M. Legal Aid, Inc., No. 18-cv-0111 MV/KK, 2019 WL 3936834, at *2 (D.N.M. Aug. 29, 2019)). Further, Plaintiffs have a duty under Rule 11 to confirm that their motion is actually opposed before representing that it is. See Fed. R. Civ. P. 11(b). Even if a party has reason to assume that a motion will be opposed, that party must still confer with the other side. In part, this is because even where such communication does not resolve all issues, it may at least narrow the issues in dispute. For instance, in the present case,

had Plaintiffs communicated with Fair and Fast before filing their motion, they might have learned that defense counsel was relying on a communication with in-house counsel, which may have altered the argument Plaintiffs made in their opening brief. In other instances, this pre- motion communication Local Rule 7.1(a) requires might avoid the unnecessary expenditure of resources attendant to litigating an issue that could have been resolved without the need for litigation. Summary denial of Plaintiffs’ motion, however, is too harsh a sanction for a violation of Rule 7.1(a) in this instance. Fair and Fast opposes the entirety of Plaintiffs’ motion to remand; therefore, Plaintiffs’ failure to confer with Fair and Fast has wrought little, if any, prejudice on

Fair and Fast. Accordingly, the Court will proceed to address the merits of Plaintiffs’ motion. See D.G. v. City of Las Cruces, No. 14-CV-368 MCA/WPL, 2015 WL 13665421, at *3 (D.N.M. Mar. 25, 2015) (“The City Defendants have pointed to no prejudice from Plaintiff’s failure to seek their concurrence before filing her motion. Moreover, in this case, denying the now fully- briefed motion serves no benefit for judicial economy. Under the circumstances, it is more appropriate that this Court now admonish Plaintiff’s counsel to request concurrence from opposing counsel before filing any motions in this Court, dispositive or otherwise, and to abide by the rules of this Court.”). 2. Unanimity Rule When a plaintiff files a civil action in state court over which the federal court would have original jurisdiction, the defendant may remove the action to federal court. 28 U.S.C. § 1441(a). “When a civil action is removed solely under section 1441(a),” as this case was, “all defendants who have been properly joined and served must join in or consent to the removal of the action.”

28 U.S.C. § 1446(b)(2)(A); see also Brady v. Lovelace Health Plan, 504 F. Supp. 2d 1170, 1172 (D.N.M. 2007) (“When there are multiple defendants, generally all must consent to join in the notice of removal in order for it to be effective.”); State Farm Fire and Cas. Co. v. Dunn- Edwards Corp., 728 F. Supp. 2d 1273, 1275 (D.N.M. 2010) (“A valid removal requires the consent of all served defendants.”). This is referred to as the unanimity rule. “The failure of one defendant to join in the notice renders the removal notice procedurally defective, which requires that the district court remand the case.” Brady, 504 F. Supp. 2d at 1172-73; see also Vasquez v. Americano U.S.A., LLC, 536 F. Supp. 2d 1253, 1257-58 (D.N.M. 2008) (“Where there are multiple defendants, all defendants served at the time of filing must join in the notice of removal

. . . . It is well established that a notice of removal fails if this procedural requirement is not met.”); City of Albuquerque v. Soto Enters., Inc., 864 F.3d 1089, 1094 (10th Cir. 2017) (confirming that noncompliance with the unanimity rule is grounds for remand). Here, only Defendants Fair and Fast and Artisan & Truckers were joined and served at the time of removal (not Pedro Casseus) and so both were required to consent to removal. Although all defendants are required to join in removal, not all defendants are required to sign the same notice of removal. See Vasquez, 536 F. Supp. 2d at 1258. Indeed, the removal statute is silent as to how or when a co-defendant should express consent for removal. See Szuszalski v. Fields, No. 1:19-CV-0250 RB-CG, 2019 WL 5964602, at *4 (D.N.M. Nov.

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Gladstone Industries Corporation and Vicki Atlasman v. Fair and Fast Logistics, Inc. and Artisan & Truckers Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gladstone-industries-corporation-and-vicki-atlasman-v-fair-and-fast-nmd-2025.