Hollis v. Holloway

CourtDistrict Court, M.D. Tennessee
DecidedFebruary 28, 2025
Docket3:24-cv-00178
StatusUnknown

This text of Hollis v. Holloway (Hollis v. Holloway) is published on Counsel Stack Legal Research, covering District Court, M.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hollis v. Holloway, (M.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION

HORACE HOLLIS, Plaintiff, Case No. 3:24-cv-00178 v. Judge Eli J. Richardson JAMES M. HOLLOWAY et al., Magistrate Judge Alistair E. Newbern Defendants.

MEMORANDUM ORDER Pro se and in forma pauperis (IFP) Plaintiff Horace Hollis, currently confined at the Tennessee Department of Correction’s (TDOC) Lois DeBerry Special Needs Facility (DSNF), initiated this action on February 12, 2024,1 raising claims against four defendants under 42 U.S.C. § 1983. After granting Hollis’s request to proceed IFP, the Court screened his complaint as required by 28 U.S.C. §§ 1915(e)(2) and 1915A, and 42 U.S.C. § 1997e. (Doc. No. 8.) The Court determined that Hollis raised colorable Eighth Amendment conditions-of-confinement claims under § 1983 against TDOC personnel “Cpl. White” and “Cpl. Murphy” and allowed those claims to advance. (Doc. No. 8, PageID# 34.) The Court dismissed all other claims and defendants. (Id. at 35.) Because Hollis was granted leave to proceed IFP, he was required to identify the defendants to be served and complete and return service packets that would allow the U.S. Marshals Service

1 Under the “prison mailbox rule[,] . . . a pro se prisoner’s [pleading] is deemed filed when it is handed over to prison officials for mailing to the court.” Brand v. Motley, 526 F.3d 921, 925 (6th Cir. 2008) (citing Richard v. Ray, 290 F.3d 810, 812–13 (6th Cir. 2002)). The rationale for this rule is that “pro se prisoners have no control over delays between the prison authorities’ receipt of [a pleading] and its filing, and their lack of freedom bars them from delivering the notice to the court clerk personally.” Houston v. Lack, 487 U.S. 266, 273–74 (1988) (emphasis in original). to effect service on his behalf. (Id. at PageID# 35.) Hollis submitted the appropriate paperwork, and the Clerk of Court issued summonses for White and Murphy. (Doc. No. 9.) Only White’s summons was returned executed (Doc. No. 11). White’s executed summons was received on May 17, 2024, and Hollis moved for entry of

default against White on August 14, 2024. (Doc. No. 14.) The Clerk of Court found that Hollis’s motion was “defective in several respects,” specifically because it was not “accompanied by the required unsworn declaration verifying proof of service, the opposing party’s failure to plead or otherwise defend the action, or defendant’s age, competency, or military status.” (Doc. No. 18, PageID# 76.) The record reflects that Murphy’s summons was returned unexecuted (Doc. No. 10). The Marshals Service made a notation on Murphy’s summons that no one by that name works at the facility where Hollis is incarcerated. (Id.) “[T]he requirement of proper service of process ‘is not some mindless technicality[,]’” Friedman v. Est. of Presser, 929 F.2d 1151, 1156 (6th Cir. 1991) (quoting Del Raine v. Carlson, 826 F.2d 698, 704 (7th Cir. 1987)), nor is it “meant to be a game or obstacle course for plaintiffs[,]”

Ace Am. Ins. Co. v. Meadowlands Dev. Ltd. P’ship, 140 F. Supp. 3d 450, 455 (E.D. Pa. 2015). Rather, it goes to the very heart of a court’s ability to hear a case. “[W]ithout proper service of process, consent, waiver, or forfeiture, a court may not exercise personal jurisdiction over a named defendant.” King v. Taylor, 694 F.3d 650, 655 (6th Cir. 2012); see also Mann v. Castiel, 681 F.3d 368, 372 (D.C. Cir. 2012) (explaining that “[s]ervice is . . . not only a means of ‘notifying a defendant of the commencement of an action against him,’ but ‘a ritual that marks the court’s assertion of jurisdiction over the lawsuit’” (citation omitted)). Where personal jurisdiction is not properly established, a court cannot exercise its authority consistent with due process of law. See Friedman, 929 F.2d at 1156–57. Federal Rule of Civil Procedure 4(m) provides that, “[i]f a defendant is not served within 90 days after the complaint is filed, the court—on motion or on its own after notice to the plaintiff—must dismiss the action without prejudice against that defendant or order that service be made within a specified time.” Fed. R. Civ. P. 4(m). The Court must extend the time for service

upon a showing of good cause, and the Court may exercise its discretion to permit late service even where a plaintiff has not shown good cause. United States v. Oakland Physicians Med. Ctr., LLC, 44 F.4th 565, 568 (6th Cir. 2022) (first citing Fed. R. Civ. P. 4(m); and then citing Henderson v. United States, 517 U.S. 654, 662 (1996)). Otherwise, Rule 4(m) mandates dismissal, either on motion or sua sponte. Fed. R. Civ. P. 4(m); see also Byrd v. Stone, 94 F.3d 217, 219 & n.3 (6th Cir. 1996). It is well established that Rule 4(m) empowers a court to dismiss complaints without prejudice “upon the court’s own initiative with notice to the plaintiff.” Hason v. Med. Bd. of Cal., 279 F.3d 1167, 1174 (9th Cir. 2002); see also Friedman, 929 F.2d at 1155 n.4 (noting that “the issue of ineffective service of process may be raised sua sponte”). Where, as here, a plaintiff proceeds IFP, “[t]he officers of the court shall issue and serve

all process, and perform all duties . . . .” 28 U.S.C. § 1915(d). Rule 4(c) “dovetails” with § 1915, Byrd, 94 F.3d at 219, by providing that “[t]he court must” “order that service be made by a United States marshal or deputy marshal or by a person specially appointed by the court” “if the plaintiff is authorized to proceed in forma pauperis under 28 U.S.C. § 1915 . . . .” Fed. R. Civ. P. 4(c)(3). Together, Rule 4(c)[(3)] and 28 U.S.C. § 1915

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Related

Houston v. Lack
487 U.S. 266 (Supreme Court, 1988)
Henderson v. United States
517 U.S. 654 (Supreme Court, 1996)
Sammie G. Byrd v. Michael P.W. Stone
94 F.3d 217 (Sixth Circuit, 1996)
John Mann v. David Castiel
681 F.3d 368 (D.C. Circuit, 2012)
Allen King v. Eric Taylor
694 F.3d 650 (Sixth Circuit, 2012)
Brand v. Motley
526 F.3d 921 (Sixth Circuit, 2008)
Vandiver v. Martin
304 F. Supp. 2d 934 (E.D. Michigan, 2004)
Abel v. Harp
122 F. App'x 248 (Sixth Circuit, 2005)
Fitts v. Sicker
232 F. App'x 436 (Sixth Circuit, 2007)
Ace American Insurance v. Meadowlands Developer Ltd. Partnership
140 F. Supp. 3d 450 (E.D. Pennsylvania, 2015)
United States v. Oakland Physicians Med. Ctr.
44 F.4th 565 (Sixth Circuit, 2022)
Friedman v. Estate of Presser
929 F.2d 1151 (Sixth Circuit, 1991)

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Bluebook (online)
Hollis v. Holloway, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hollis-v-holloway-tnmd-2025.