Guillory v. Denny's

CourtDistrict Court, S.D. Texas
DecidedFebruary 5, 2025
Docket4:24-cv-04099
StatusUnknown

This text of Guillory v. Denny's (Guillory v. Denny's) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guillory v. Denny's, (S.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT February 05, 2025 FOR THE SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

§ Patrick Guillory, § § Plaintiff, § § Civil Action No. 4:24-cv-04099 v. § § Denny’s, § § Defendant. §

MEMORANDUM AND RECOMMENDATION AND ORDER On January 16, 2024, Plaintiff Patrick Guillory filed a motion for default judgment, invoking Fed. R. Civ. P. 55. Dkt. 11. Guillory asserts that Defendant Denny’s has not appeared after being served with a copy of the summons and the complaint. See id. at 2. Relatedly, Guillory submitted a document requesting that Court direct the U.S. Marshals to serve his motion for default judgment on Denny’s because personnel at a specific Denny’s establishment blocked his communications and called the police when he attempted to serve the motion in person. Dkt. 15. Guillory also filed a motion requesting to appear in person at the initial conference, currently set for February 21, 2025. Dkt. 16. As explained below, because Guillory has not adequately proved that he properly served Denny’s with the summons and complaint, his request for default judgment should be denied. But the Court grants Guillory additional time to effectuate service, reschedules the initial conference, and grants his

request to hold the conference in person. Guillory’s further request for the U.S. Marshals to serve his motion for default judgment is denied as moot. Analysis I. Guillory is not entitled to default judgment because the record does not show that Denny’s was properly served. Guillory’s lack of proof that Denny’s was properly served forecloses his request for default judgment. But as noted below, Guillory is granted

additional time to effectuate proper service of process. Default proceedings involve three steps: default, entry of default, and default judgment. See Fed. R. Civ. P. 55. A default occurs “when a defendant has failed to plead or otherwise respond to the complaint within the time

required by the Federal Rules.” N.Y. Life Ins. Co. v. Brown, 84 F.3d 137, 141 (5th Cir. 1996). “An entry of default is what the clerk enters when a plaintiff establishes the default by affidavit or otherwise pursuant to Rule 55(a).” Axcess Global Sciences, LLC v. Ozcan Grp., Inc., 2024 WL 3259700, at *1 (S.D.

Tex. July 1, 2024). A plaintiff can then apply for a default judgment under Rule 55(b)(2). See id. District courts have discretion to determine whether entry of default judgment is warranted. See Lewis v. Lynn, 236 F.3d 766, 767 (5th Cir. 2001). But the Fifth Circuit instructs that “[d]efault judgments are a drastic remedy, not favored by the Federal Rules and resorted to by courts only in extreme

situations.” Sun Bank of Ocala v. Pelican Homestead & Savings Ass’n, 874 F.2d 274, 276 (5th Cir. 1989)). A plaintiff “is not entitled to a default judgment as a matter of right,” even if the defendant “is technically in default.” Lewis v. Lynn, 236 F.3d 766, 767 (5th Cir. 2001) (quoting Ganther v. Ingle, 75

F.3d 207, 212 (5th Cir. 1996)). Moreover, a plaintiff cannot obtain a default judgment until the complaint and summons were properly served. See Roor Int’l v. A1 Smoke Shop Inc., 2019 WL 6330543, at *2 (S.D. Tex. Oct. 18, 2019), adopted by 2019 WL

6330483 (S.D. Tex. Nov. 25, 2019). Without proof of proper service, default judgment is procedurally improper and must be denied. See Prince v. Jaworowski, 2024 WL 4645067, at *1 (S.D. Tex. Oct. 17, 2024), adopted by 2024 WL 4647716 (S.D. Tex. Oct. 31, 2024).

Here, the clerk has yet to enter a default. But even if default had been entered, Guillory still would not be entitled to a default judgment because his proof of service is deficient. Public records reflect that Denny’s is a Delaware corporation with its

principal place of business in South Carolina.1 One way to serve a corporation

1 See Form 8-K, Denny’s Corporation (January 13, 2025), available at https://d18rn0p25nwr6d.cloudfront.net/CIK-0000852772/f67bc85a-0b2c-4af2-9c3c- (or other business entity) is by delivery “to an officer, a managing or general agent, or any other agent authorized by appointment or by law to receive service

of process.” Fed. R. Civ. P. 4(h)(1)(A) (emphasis added). Delivery of the summons and complaint “to a purported agent does not constitute service on the would-be principal, even if the ‘agent’ represents himself to be so authorized or accepts service.” Lisson v. ING Groep N.V., 262 F. App’x 567,

569 (5th Cir. 2007) (per curiam) (emphasis added); see also Fyfee v. Bumbo Ltd., 2009 WL 2996885, at *3 (S.D. Tex. Sept. 16, 2009) (quoting this principle and finding no proof that an authorized agent of the corporation was served). Alternatively, a corporation or other entity can be served “in the manner

prescribed by Rule 4(e)(1) for serving an individual.” Fed. R. Civ. P. 4(h)(1). That provision incorporates state law “where the district court is located or where service is made.” Fed. R. Civ. P. 4(e)(1). Like federal law, Texas law requires proof that the person who served “was in fact” the entity’s registered

agent or was “otherwise authorized to accept service” on the entity’s behalf. See Tubo Rests., LLC v. Reid’s Refrigeration Inc., 657 S.W.3d 490, 495, 499 (Tex. App.—El Paso 2022, no pet.) (addressing service on a corporation); see also, e.g., Hercules Concrete Pumping Serv., Inc. v. Bencon Mgmt. & Gen.

d1875415392a.pdf (last visited Feb. 5, 2025). See also Denny’s Corporation, State of Delaware, Department of State: Division of Corporations, https://icis.corp.delaware.gov/ecorp/entitysearch/NameSearch.aspx (last visited Feb. 5, 2025). Contracting Corp., 62 S.W.3d 308, 310 (Tex. App—Houston [1st Dist.] 2001, pet. denied) (reversing default judgment because there was no showing that

the individual who was served “is in fact the [defendant corporation’s] registered agent for service of process”). In this case, the return of service indicates that the complaint and summons were served on “Alan Tran (General Manager)” of a Denny’s location

at 12697 North Gessner, Houston, Texas 77064. Dkt. 5. But there is no indication that Denny’s designated or authorized Mr. Tran to accept service on Denny’s behalf.2 And even if the specific Denny’s location were independently owned or operated by some other business entity—which nothing in the record

addresses—Guillory proffers no evidence suggesting that Mr. Tran is the authorized agent for service of process on that entity. Without the requisite proof that the summons and complaint were duly served on someone with authority to accept service for Denny’s, Guillory cannot meet his burden to

show that he is entitled to default judgment. At this point, more than 90 days have elapsed since Guillory filed his complaint. Yet the record does not show that Denny’s has been properly served, which would authorize this Court to dismiss Guillory’s claims. See Fed.

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Related

Ganther v. Ingle
75 F.3d 207 (Fifth Circuit, 1996)
New York Life Insurance v. Brown
84 F.3d 137 (Fifth Circuit, 1996)
Lewis v. Lynn
236 F.3d 766 (Fifth Circuit, 2001)
Lisson v. ING Groep N.V.
262 F. App'x 567 (Fifth Circuit, 2007)
Alfred Ortiz, III v. City of San Antonio Fire Dept
806 F.3d 822 (Fifth Circuit, 2015)

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