Groff Tractor Mid Atlantic LLC v. Rubble Master Americas Corp

CourtDistrict Court, N.D. Texas
DecidedMay 28, 2025
Docket3:25-cv-00197
StatusUnknown

This text of Groff Tractor Mid Atlantic LLC v. Rubble Master Americas Corp (Groff Tractor Mid Atlantic LLC v. Rubble Master Americas Corp) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Groff Tractor Mid Atlantic LLC v. Rubble Master Americas Corp, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

GROFF TRACTOR § MID ATLANTIC, LLC, § § Plaintiff, § § v. § Civil Action No. 3:25-CV-197-L § RUBBLE MASTER AMERICAS CORP., § § Defendant. §

MEMORANDUM OPINION AND ORDER

Before the court is Plaintiff’s Motion to Remand (“Motion” or “Motion to Remand”) (Doc. 6), filed February 17, 2025. For the reasons herein explained, the court grants the Motion (Doc. 6) and remands this action to state court. I. Discussion Plaintiff Groff Tractor Mid Atlantic, LLC (“Plaintiff” or “Groff”) contends that the removal of this action to federal court by Defendant Rubble Master Americas Corp. (“Defendant”) on January 27, 2025, was untimely under 28 U.S.C § 1446(b)(1) because the case was removed more than thirty days after Defendant received notice of the lawsuit on December 13, 2024, the date Defendant was served with process. Plaintiff further contends that, even if Defendant disputes being served on this date, the e-mail sent its attorney on December 20, 2024, shows that Defendant had notice of this lawsuit by this date. Plaintiff, therefore, requests that the court remand this action to state court. Section 1446(b)(1) provides that: [t]he notice of removal of a civil action or proceeding shall be filed within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based, or within 30 days after the service of summons upon the defendant if such initial pleading has then been filed in court and is not required to be served on the defendant, whichever period is shorter.

Thus, Defendant was required to remove this action the earlier of thirty days from service of Plaintiff’s Petition or receiving notice of this lawsuit. See id. Defendant counters that its removal of this action was timely or, even if untimely, Plaintiff is estopped from arguing otherwise because: 24. In this case, the time to respond to the lawsuit was extended by twenty days. This renders the removal timely. Defendant requested an extension of time in this lawsuit. Plaintiff granted Defendant’s request for an extension of time to respond. Exh. 20, APP. 256-258; Exh. 21, APP. 259-260[.]

25. In addition, a defendant does not lose the[] right to remove when a plaintiff waives the time limit, or if a defendant can show some equitable reason why that limit should not be applied. Brown v. Demco, Inc., 792 F.2d 478, 481 (5th Cir. 1986). Furthermore, the courts have recognized that the thirty-day time frame for removal prescribed by 28 U.S.C. § 1446(b) may be extended through estoppel. Nicola Prods. Corp. v. Showart Kitchens, Inc., 682 F. Supp. 171, 173 (E.D.N.Y. 1988)[.]

26. Here, Plaintiffs are estopped from rem[and]ing this action to state court. On December 20, 2024, immediately after receiving notice of this action filed in state court and prior to the expiration of § 1446(b)’s time limit, Defense Counsel reached out to Plaintiff’s counsel to request a twenty (20) day extension of time to respond. Exh. 20, APP. 256-258; Exh. 21, APP. 259-260. Plaintiff’s Counsel immediately responded to the correspondence granting said extension. Id. Defendant relied upon Plaintiff’s agreement and filed its Notice of Removal on January 27, 2024, which was within the time agreed upon by the parties. Evidently, Defendant relied on Plaintiff’s representations to its detriment, as Plaintiff is now moving to remand despite Defendant complying with the parties’ agreed upon extension of time.

27. In fact, Plaintiffs have been overtly disingenuous before this court by omitting their response to Defense Counsel’s email requesting such an extension. ECF Doc. 006-2, p. 5. As shown in the full email correspondence between Defense Counsel and Plaintiff’s Counsel attached hereto as Exhibit 20, Plaintiff granted Defendant’s request for an extension of time to respond to this lawsuit within minutes of same being requested. Exh. 20, APP. 256-258; Exh. 21, APP. 259-260. Plaintiff’s deliberate omission of its response to Defense Counsel directly reflects on its credibility. 28. Courts have held that a plaintiff is estopped from moving to remand an action when a defendant untimely files its notice of removal due to the duplicity of the plaintiff. Staples v. Joseph Morton Co., 444 F. Supp. 1313-14 (E.D.N.Y. 1978). It would be inequitable to apply the time limitations of 28 U.S.C. § 1446(b) in a situation like the one at hand, where Plaintiff has deceived the Court and Defendant in order to hinder Defendant from asserting its statutory right to remove. Id.

Def.’s Resp. ¶¶ 24-28. In addition, Defendant argues that the thirty-day deadline is not jurisdictional, and courts have held that the thirty-day deadline under section 1446(b) can be extended under certain equitable circumstances such as those referenced. Defendant is correct that “[t]imeliness of removal is a procedural rather than a jurisdictional issue” and, as such, it “may be waived by an untimely objection.” In re TXNB Internal Case, 483 F.3d 292, 299 (5th Cir. 2007) (citing Hartford Accident & Indem. Co. v. Costa Lines Cargo Servs., Inc., 903 F.2d 352, 359-60 (5th Cir. 1990)). Plaintiff, however, timely moved to remand this action within twenty days of it being removed by Defendant. See 28 U.S.C. § 1477 (requiring motions to remand to be filed within thirty days after the filing of a notice of removal unless based on subject matter jurisdiction). Consequently, the only issue remaining is whether Defendant’s removal was timely. Defendant does not dispute being served with the Plaintiff’s Petition on December 13, 2024. Accordingly, its deadline to remove this action was Monday, January 13, 2025. See 28 U.S.C § 1446(b)(1); see also Fed. R. Civ. P. 6(a)(1)(C) (in computing deadlines, if the last day of the period falls on a weekend or holiday, the deadline is the next day that does not fall on a weekend or holiday). The e-mail submitted by Defendant in support of its response to Plaintiff’s Motion reflects that Plaintiff agreed to give Defendant a “20[-]day extension to file an Answer” in this action. Def.’s App. 257 (Doc. 12). The e-mail, however, says nothing about extending Defendant’s removal deadline. Defendant apparently conflates Plaintiff’s agreement to extend its time to file an answer with its statutory deadline to remove this action under § 1446(b)(1). An answer is not the equivalent of a notice of removal, and Defendant offers no explanation or legal authority to support its suggestion that an extension of its deadline to file an answer to Plaintiff’s Petition under state or federal rules of civil procedure also extended its statutory deadline to file a notice of removal under § 1446(b)(1)

as established by Congress. For the same reason, its estoppel argument is unfounded and without merit, and the cases it relies on are distinguishable.

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Groff Tractor Mid Atlantic LLC v. Rubble Master Americas Corp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/groff-tractor-mid-atlantic-llc-v-rubble-master-americas-corp-txnd-2025.