Herminio Castillo, Jr. v. Chad Thomas, et al.

CourtDistrict Court, S.D. Texas
DecidedOctober 20, 2025
Docket2:24-cv-00210
StatusUnknown

This text of Herminio Castillo, Jr. v. Chad Thomas, et al. (Herminio Castillo, Jr. v. Chad Thomas, et al.) 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
Herminio Castillo, Jr. v. Chad Thomas, et al., (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT October 20, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk CORPUS CHRISTI DIVISION

HERMINIO CASTILLO, JR., § § Plaintiff, § § VS. § CIVIL ACTION NO. 2:24-CV-00210 § CHAD THOMAS, et al., § § Defendants. §

MEMORANDUM AND RECOMMENDATION Pending before the Court is Defendant Chase Thomas’s Motion to Dismiss Plaintiff Herminio Castillo’s claims for failure to state a claim for which relief can be granted, insufficient process, and insufficient service of process. (D.E. 28). The motion was referred to the undersigned for submission of a recommendation to the District Judge. Having considered the motion, responses, and applicable law, the undersigned recommends that the motion be DENIED for the reasons set out below. I. BACKGROUND On September 16, 2024, Plaintiff filed his civil rights complaint pursuant to 42 U.S.C. § 1983., naming Defendants Jim Wells County, Texas (“the County”), and Chad Thomas. (D.E. 1). The complaint alleged that Chad Thomas, a former jailer at Jim Wells County Jail while Plaintiff was a pretrial detainee, violated Plaintiff’s constitutional rights when he assaulted him on two occasions. Id. On October 14, 2024, Plaintiff requested the issuance of summons for the County and Chad Thomas. (D.E. 50). On October 15, 2024, the summonses were issued by the Clerk of Court. (D.E. 51). On November 5, 2024, the County filed a motion to dismiss,

which the District Court subsequently granted. (D.E. 7, 22, 35). On December 12, 2024, the District Court held an Initial Pretrial Conference and inquired as to the status of Defendant Chad Thomas and why he had not been served with process. Plaintiff’s counsel informed the Court that there had been some “difficulty locating” Chad Thomas and that counsel would endeavor to accomplish service “this

week.” The Court admonished Plaintiff’s counsel that the 90-day deadline to accomplish service would run within the week, the Court was limited in what it could do if service was not accomplished within the 90 days, and that Plaintiff’s counsel was “on notice” to accomplish service within the 90-day period. Later the same day, Plaintiff’s counsel filed an Unopposed Amended Complaint and

a Request for Issuance of Summons, correcting Defendant Chad Thomas to Defendant Chase Robert Thomas (“Thomas”). (D.E. 15, 16). The Clerk issued the summons for Defendant Chase Thomas on December 13, 2024. (D.E. 19). Over five months went by with no service on Thomas, no notice to the Court regarding issues with serving Thomas, and no request to authorize alternative service by

Plaintiff’s counsel. On May 28, 2025, the District Court sua sponte issued an Order for Proof of Service (D.E. 26), directing Plaintiff’s counsel to provide the Court with proof of service on Thomas on or before June 4, 2025. (D.E. 24). Plaintiff’s counsel filed a Motion for Extension of Time to Effect Service on June 2, 2025, arguing that the time to serve Thomas should be extended under Rule 4(m) for good cause or excusable neglect. (D.E. 25). On June 3, 2025, the District Court granted Plaintiff’s Motion for Extension of Time

for Service and gave Plaintiff an extension until June 23, 2025. (D.E. 26). Although the District Court made no specific findings in the order, the Court did specifically grant Plaintiff’s Motion for an Extension of Time for Service until June 23, 2025, citing Rule 4(m). Plaintiff’s counsel accomplished service on Thomas on June 3, 2025. (D.E. 27).

On June 24, 2025, Thomas filed the pending motion to dismiss. (D.E.28). II. SUMMARY OD THE ARGUMENT In his motion to dismiss, Thomas argues that Plaintiff’s case should be dismissed for two reasons. First, he argues that Plaintiff’s claim is barred by the statute of limitations because, although he filed the case on September 16, 2024, before the limitations period

expired, he initially named Chad Thomas as a defendant and did not file suit against Chase Thomas until December 12, 2024. The alleged actions causing Plaintiff injury occurred on October 2, 2022, and therefore, he did not file this suit against Chase Thomas within the two-year limitations period. (D.E. 28, pgs. 4-5). Second, Thomas submits that Plaintiff did not timely effect service on him under Rule 4(m). Id. at 6-7. Thomas states that Plaintiff

did not serve him in this case until June 3, 2025, almost six months after filing the Amended Complaint, eight months after the statute of limitations expired, and almost nine months after filing his original complaint. Id. Plaintiff Castillo filed a response to Thomas’s motion to dismiss. (D.E. 29). Plaintiff contends that the Thomas’s argument regarding statute of limitations is not valid because the Original Complaint contained a misnomer regarding Thomas’s correct first

name. Plaintiff maintains that the statute of limitations was tolled and the subsequent amendment of the complaint related back to the date of the original filing. Id. at 2. Plaintiff also states that Defendant Thomas has waived any plausibility argument under Twombly/Iqbal because he failed to fully brief the issue. Plaintiff submits that a criminal indictment against Thomas defeats any plausibility complaint in this case. Id. at 3-5.

Lastly, Plaintiff contends that the District Court in this case has already decided that good cause existed to extend the time for service, defeating any timeliness issue regarding when Thomas was served. Id. at 5-6. In his reply, Thomas argues that, with regard to the misnomer issue, the statute of limitations is tolled for a misnamed party only if he is timely served with notice of the suit.

(D.E. 32, pg. 2). Defendant Thomas contends that the statute of limitations is not tolled in this case because he was not served with notice of the lawsuit at the time of the amended complaint. Id. at 3. Defendant Thomas also maintains that Plaintiff has not shown good cause or due diligence for his failure to serve Defendant in accordance with Rule 4(m). III. DISCUSSION

a. Applicable Statute of Limitations The statute of limitations for a suit brought under § 1983 is determined by the general statute of limitations governing personal injuries in the forum state. See Pete v. Metcalfe, 8 F.3d 214, 217 (5th Cir.1993). Since Texas has a two-year statute of limitations for personal injury claims, see Burrell v. Newsome, 883 F.2d 416, 418 (5th Cir.1989), Castillo had two years to file suit from the date his claim accrued. Piotrowski v. City of

Houston, 237 F.3d 567, 576 (5th Cir. 2001). It is undisputed that the applicable statute of limitations under Texas law for Castillo’s claims is two years. See Tex. Civ. Prac. & Rem. Code Ann. § 16.003 (“[A] person must bring suit for ... personal injury ... not later that two years after the day the cause of action accrues.”). Under Texas law, in order to “bring suit” on a state law claim within the

two-year statute of limitations, the plaintiff must not only file suit within the limitations period but must also use due diligence in serving the defendant with process if the defendant is served after the expiration of the limitations period. Gant v. DeLeon, 786 S.W.2d 259, 260 (Tex. 1990) (per curiam); Gonzales v. Wyatt, 157 F.3d 1016, 1021 n. 1 (5th Cir. 1998) (holding that the Texas statute of limitations and specifically the due

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Herminio Castillo, Jr. v. Chad Thomas, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/herminio-castillo-jr-v-chad-thomas-et-al-txsd-2025.