Howarth v. Patterson

CourtDistrict Court, D. Arizona
DecidedAugust 8, 2019
Docket2:19-cv-00726
StatusUnknown

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

Bluebook
Howarth v. Patterson, (D. Ariz. 2019).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Morgan Howarth, No. CV-19-00726-PHX-ESW

10 Plaintiff, ORDER

11 v.

12 Ryan Patterson, et al.,

13 Defendants. 14 15 16 This Order sets forth the Court’s rulings on a number of pending Motions (Docs. 17 40, 41, 43, 46, 47, 52, and 53). 18 I. DISCUSSION 19 A. Defendants’ “Motion for a Bond Requirement for Plaintiff” (Doc. 40) and 20 Plaintiff’s “Motion to Strike Defendants’ Untimely Reply, and to Strike or Disregard Arguments Raised for the First Time Therein” (Doc. 46) 21 Pursuant to Local Rule of Civil Procedure (“LRCiv”) 54.1(c), Defendants filed a 22 Motion (Doc. 40) requesting that the Court order Plaintiff to post a $25,000 bond for 23 Defendants’ fees and taxable costs incurred in this action.1 (Doc. 40). Plaintiff filed his 24 Response (Doc. 42) on June 21, 2019. On July 1, 2019, Defendants filed their Reply (Doc. 25 26 1 LRCiv 54.1(c) states: “In every action in which the plaintiff was not a resident of 27 the District of Arizona at the time suit was brought, or, having been so, afterwards removed from this District, an order for security for costs may be entered upon application therefor 28 within a reasonable time upon notice.” 1 45). Contrary to Plaintiff’s assertion in his Motion to Strike (Doc. 46), Defendants’ Reply 2 is timely. Plaintiff correctly recounts that the rules provide a seven-day deadline for filing 3 a reply in support of a motion. Plaintiff, however, neglects to consider that Federal Rule 4 of Civil Procedure 6(d) states: When a party may or must act within a specified time after 5 service and service is made under Rule 5(b)(2)(C), (D), (E), or 6 (F), 3 days are added after the period would otherwise expire under Rule 6(a). 7 Rule 5(b)(2)(E) includes service by electronic means. Seven days from Plaintiff’s June 21, 8 2019 Response (Doc. 42) is June 28, 2019. After adding another three days pursuant to 9 Rule 6(d), Defendants’ reply deadline was July 1, 2019. Although Plaintiff alternatively 10 argues that the Court should strike or disregard arguments raised for the first time in 11 Defendants’ Reply (Doc. 45), the Court finds that the arguments contained therein are in 12 response to issues raised in Plaintiff’s Response (Doc. 42). The Court will deny Plaintiff’s 13 Motion to Strike (Doc. 46).2 For the reasons discussed below, the Court will grant 14 Defendants’ Motion for a Bond (Doc. 40). 15 “There is no specific provision in the Federal Rules of Civil Procedure relating to 16 security for costs. However, the federal district courts have inherent power to require 17 plaintiffs to post security for costs.” Simulnet E. Assoc. v. Ramada Hotel Operating Co., 18 37 F.3d 573, 574 (9th Cir. 1994). “Typically federal courts, either by rule or by case-to 19 case determination, follow the forum state’s practice with regard to security for costs, as 20 they did prior to the federal rules; this is especially common when a non-resident party is 21 involved.” Id. (internal quotation marks and citation omitted). The historical purpose of 22 bond requirements is “to help resident defendants collect costs when victorious against 23 non-resident plaintiff whose property was beyond the reach of the court.” Gay v. Chandra, 24 682 F.3d 590, 594 (7th Cir. 2012). 25 26 2 The Court observes that many of Defendants’ briefs fail to comply with LRCiv 27 7.1(b)(1), which requires all original documents filed with the Clerk of Court to be in a “fixed-pitch type size no smaller than ten (10) pitch (10 letters per inch) or in a proportional 28 font size no smaller than 13 point, including footnotes.” Continued failure to comply with LRCiv 7.1(b)(1) will result in a filed brief being stricken. 1 In Simulnet, the Ninth Circuit reviewed whether the district court abused its 2 discretion by dismissing a case after the plaintiffs failed to post a $500,000 cost bond, 3 which was imposed five days before trial was set to commence. 37 F.3d at 573. In holding 4 that the district court abused its discretion, the Ninth Circuit stated that the district court: knew that the plaintiffs could not post the bond, but imposed 5 the bond because of its belief that the defendants would prevail 6 in the jury trial, even though the court declined to hold the plaintiffs’ claims were vexatious. In practical effect, this 7 amounted to a judgment as a matter of law in a case where 8 discovery proceedings revealed there was a genuine issue of material fact to be determined by the jury. 9 Id. at 576. The Ninth Circuit explained that “[i]n order to avoid depriving a plaintiff of 10 access to the courts by a security bond requirement, the courts in some cases must strike a 11 delicate balance.” Id. The Ninth Circuit did not hold that district courts must use a specific 12 balancing test, but noted that the “First Circuit made an illuminating comment” regarding 13 the issue. Id. In Aggerwal v. Ponce School of Medicine, 745 F.2d 723, 727-28 (1st Cir. 14 1984), the First Circuit weighed the following three factors in determining whether a 15 district court abused its discretion in requiring a security for costs: (i) the degree of 16 probability or improbability of success on the merits, and the background and purpose of 17 the suit; (ii) the reasonable extent of the security to be posted, if any, viewed from the 18 defendant’s perspective; and (iii) the reasonable extent of the security to be posted, if any, 19 viewed from the nondomiciliary plaintiff’s perspective. Aggerwal, 745 F.2d at 727-28. 20 The First Circuit further explained that: 21 just as factors such as the absence of attachable property within 22 the district or the conduct of the parties may bear on a defendant’s legitimate need for the prophylaxsis of a bond, so 23 too, a plaintiff’s ability to post surety for costs must weigh in 24 the balance when the third figure of the equation is tabulated . . . . The district court, in the exercise of its sound discretion, 25 must settle upon an assurance which is fair in the light not only 26 of the case itself and of the exigencies faced by the defendant, but also fair when illuminated by the actual financial situation 27 of the plaintiff. 28 Id. at 728. 1 Here, given the early stage of litigation, the Court does not conclude that either party 2 is more likely to succeed. Defendants reasonably assert that a bond is required because 3 Plaintiff does not reside in the State of Arizona and does not own any property within 4 Arizona out of which a judgment for costs can be satisfied. Plaintiff states that he has 5 substantial equity in his out-of-state residence. (Doc. 42 at 7). Plaintiff has not shown that 6 he cannot afford to post a bond. 7 “[I]t is neither unjust nor unreasonable to expect a suitor ‘to put his money where 8 his mouth is[.]’” Simulnet, 37 F.3d at 576 (quoting Aggarwal 745 F.2d at 728). After 9 considering the circumstances of this action and the parties, the Court concludes that the 10 balance of the relevant factors weigh in favor of requiring Plaintiff to post a $25,000 11 security bond in this case. Plaintiff’s Motion (Doc. 40) will be granted. 12 B. Plaintiff’s “Motion for Leave to Join Parties and File a First Amended Complaint” (Doc. 41) and Defendants’ “Motion to Extend Time for 13 Defendants’ Opposition to Amend” (Doc. 47) 14 On June 17, 2019, Plaintiff timely moved for leave of Court to file a First Amended 15 Complaint. (Doc. 41). Defendants’ deadline for responding was July 5, 2019.3 On July 16 2, 2019, Defendants filed a “Motion to Extend Time for Defendants’ Opposition to 17 Amend” (Doc. 47). For good cause shown, the Court will grant Defendants’ Motion (Doc.

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Howarth v. Patterson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howarth-v-patterson-azd-2019.