Hawkins v. International Paper Co

CourtDistrict Court, W.D. Louisiana
DecidedMarch 26, 2025
Docket5:24-cv-00868
StatusUnknown

This text of Hawkins v. International Paper Co (Hawkins v. International Paper Co) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hawkins v. International Paper Co, (W.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA SHREVEPORT DIVISION

FREDERICK HAWKINS CIVIL ACTION NO. 24-868

VERSUS JUDGE EDWARDS

INTERNATIONAL PAPER CO ET AL MAG. JUDGE HORNSBY

MEMORANDUM RULING & ORDER

Before the Court is a Motion to Dismiss filed by defendant International Paper Company (“IP” or “Defendant”).1 IP is moving to dismiss based on improper venue, insufficient service of process, and failure to state a claim upon which relief can be granted. The Motion is unopposed. For the reasons stated herein, the Motion is GRANTED. I. BACKGROUND On May 30, 2024, Frederick Hawkins (“Mr. Hawkins” or “Plaintiff”) filed suit against IP and an entity named “Shreveport Preprint and Coating Plant” in the 1st Judicial District Court, Caddo Parish, Louisiana.2 In his petition, Mr. Hawkins alleges that IP is liable for injuries he sustained on June 3, 2023, while attempting to unload sulfuric acid at an IP industrial facility.3 Mr. Hawkins alleges that IP was negligent in failing to ensure that the delivery valve and apparatus he used was free from pressure and ready to accept bulk chemical liquids.4 IP asserts the facility where these events took place was the Mansfield Mill, located in DeSoto Parish.5

1 R. Doc. 10. 2 R. Doc. 1-2. 3 Id. On June 27, 2024, IP removed the case to this Court based on diversity jurisdiction.6 Mr. Hawkins filed a motion to remand on July 19, 2024, arguing removal was improper because "Shreveport Preprint and Coating Plant," which he

claimed was involved in the harmful conduct, did not join in or consent to removal.7 The Report and Recommendation from the magistrate judge on the motion to remand recommended denying the motion.8 That recommendation was adopted by the Court.9 The Court determined that "Shreveport Preprint and Coating Plant" is not a separate legal entity capable of being sued, making it an improperly joined defendant.10 Because improperly joined defendants do not need to consent to removal, IP properly

removed the case without its consent.11 On the same day Mr. Hawkins filed his motion to remand, IP filed the instant Motion to Dismiss.12 IP asserts that the suit was filed in an improper venue and that service was not made on IP within the prescriptive period.13 As a result, IP asserts prescription was never interrupted, and Mr. Hawkins’ claims are now time-barred.14 Accordingly, IP seeks to dismiss the action. Mr. Hawkins has not filed an opposition, and the Motion is considered unopposed.15

II. LEGAL STANDARD

6 R. Doc. 1 at 3. 7 R. Doc. 12. 8 R. Doc. 15. 9 R. Doc. 16. 10 R. Doc. 15 at 3. 11 Id. 12 R. Doc. 10. 13 R. Doc. 10 at 1–2. A motion to dismiss under Rule 12(b)(6) of the Federal Rules of Civil Procedure is viewed with disfavor and is rarely granted.16 The complaint must be liberally construed in favor of the plaintiff, and all facts pleaded in the complaint must be

taken as true.17 The complaint must, however, contain sufficient factual allegations, as opposed to legal conclusions, to state a claim for relief that is “plausible on its face.”18 When there are well-pleaded factual allegations, a court should presume they are true, even if doubtful, and then determine whether they plausibly give rise to an entitlement to relief.19 Additionally, regardless of how well-pleaded the factual allegations may be, they must demonstrate that the plaintiff is entitled to relief under

a valid legal theory.20 In considering a motion to dismiss, a court must ordinarily limit itself to the contents of the pleadings and attachments thereto.21 “Documents that a defendant attaches to a motion to dismiss are [also] considered part of the pleadings if they are referred to in the plaintiff's complaint and are central to her claim.”22 Indeed, any documents attached to the briefing on a motion to dismiss may be considered by the Court if the documents are sufficiently referenced in the complaint and no party

questions their authenticity.23

16 Harrington v. State Farm Fire & Cas. Co., 563 F.3d 141, 147 (5th Cir. 2009). 17 Id. 18 See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 19 Id. at 679. 20 See Neitzke v. Williams, 490 U.S. 319, 327 (1989); McCormick v. Stalder, 105 F.3d 1059, 1061 (5th Cir. 1997). 21 Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498 (5th Cir. 2000) (citing Fed. R. Civ. P. 12(b)(6)). 22 Id. (quoting Venture Assocs. Corp. v. Zenith Data Sys. Corp., 987 F.2d 429, 431 (7th Cir. 1993)); see The defense of prescription may be raised in a motion to dismiss brought pursuant to Rule 12(b)(6).24 An action is subject to dismissal under Rule 12(b)(6) when “it is evident from the plaintiff's pleadings that the action is barred and the pleadings

fail to raise some basis for tolling or the like.”25 III. LAW AND ANALYSIS At the time of this incident, under Louisiana law, a delictual action such as this one was subject to a prescriptive period of one year.26 Thus, the prescriptive period for Mr. Hawkins’ claim expired June 3, 2024. IP argues that Plaintiff’s claims have prescribed because the suit was filed in

an improper venue and service was not timely made within the prescriptive period. As a result, IP contends that prescription was never interrupted, and the claim is now time-barred. La. Civ. Code art. 3462 states: Prescription is interrupted when the owner commences action against the possessor, or when the obligee commences action against the obligor, in a court of competent jurisdiction and venue. If action is commenced in an incompetent court, or in an improper venue, prescription is interrupted only as to a defendant served by process within the prescriptive period.

Under Louisiana law, prescription is interrupted when an action is filed in a court of competent jurisdiction and proper venue.27 If an action is filed in an improper venue, prescription is not interrupted unless service is made within the prescriptive period.28

24 See Tigert v. Am. Airlines Inc., 390 F. App'x 357 (5th Cir. 2010) (unpublished) (affirming dismissal of a time-barred claim under 12(b)(6)). 25 Jones v. Alcoa, Inc., 339 F.3d 359, 366 (5th Cir. 2003). 26 La. Civ. Code art. 3492. To determine whether prescription was interrupted when Mr. Hawkins filed his petition on May 30, 2024, the Court must first decide whether venue was proper. If venue was improper, the Court must then determine whether service was timely

made within the prescriptive period. a. Venue IP asserts that because Mr. Hawkins filed suit in Caddo Parish, venue was improper.29 IP contends that DeSoto Parish was the parish of proper venue as it is where both the accident occurred and where IP’s principal Louisiana business establishment is located.30

Under Louisiana’s general venue provision, La. Code Civ. Proc. art.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McCormick v. Stalder
105 F.3d 1059 (Fifth Circuit, 1997)
Collins v. Morgan Stanley Dean Witter
224 F.3d 496 (Fifth Circuit, 2000)
Harrington v. State Farm Fire & Casualty Co.
563 F.3d 141 (Fifth Circuit, 2009)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Mary Tigert v. American Airlines, Inc.
390 F. App'x 357 (Fifth Circuit, 2010)
Moore v. Kmart Corp.
884 F. Supp. 217 (E.D. Louisiana, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Hawkins v. International Paper Co, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hawkins-v-international-paper-co-lawd-2025.