Hulet v. County of Tuolumne

CourtDistrict Court, E.D. California
DecidedJanuary 18, 2024
Docket1:23-cv-01217
StatusUnknown

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

Bluebook
Hulet v. County of Tuolumne, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 GRANT HULET, Case No. 1:23-cv-01217-HBK 12 Plaintiff, ORDER GRANTING MOTION FOR SERVICE EXPENSES1 13 v. (Doc. No. 9) 14 COUNTY OF TUOLUMNE and TUOLUMNE COUNTY SHERIFFS 15 OFFICE, 16 Defendants. 17 18 Pending before the Court is Plaintiff’s Motion for Service Expenses. (Doc. No. 9, 19 “Motion”). Defendants filed an Opposition (Doc. No. 13), and Plaintiff filed a Reply (Doc. No. 20 16). For the reasons set forth below, the Court grants Plaintiff’s Motion. 21 BACKGROUND 22 On August 14, 2023, Plaintiff initiated this action by filing a civil rights complaint under 23 42 U.S.C. § 1983 alleging various constitutional violations by Defendants. (See Doc. No. 1). On 24 August 23, 2023, Plaintiff’s counsel sent letter packets by mail to Defendants, containing (1) a 25 Notice of a Lawsuit and Request to Waive Service of a Summons; (2) Waiver of the Service of 26 Summons (two copies with a pre-paid return envelope); (3) a copy of the Complaint; (4) a Civil 27 1 This pretrial matter has been referred to the undersigned pursuant to 28 U.S.C. § 636 (b)(1)(A). Local 28 Rule 302(a). 1 Cover Sheet; (5) a Summons; and various informational documents. (Doc. No. 9-1 at 2; Doc. No. 2 13 at 2). Defendants were directed to waive service within 30 days of the date indicated on the 3 Notice form, i.e., by September 22, 2023. (Doc. No. 9-1 at 2.). Defendants did not return the 4 waivers. (Id.). 5 On October 10, 2023, Plaintiff’s counsel arranged for personal service on Defendants. 6 (Doc. No. 9-1 at 2). On October 10 and 12, 2023, Defendants were personally served with 7 process, at a combined cost of $180. (Doc. No. 9-1 at 2; Doc. No. 13 at 2). On November 13, 8 2023, Defendants filed a Motion to Dismiss. (Doc. No. 8). The same day, Plaintiff filed the 9 instant Motion seeking reimbursement of costs and attorney fees under Federal Rule of Civil 10 Procedure 4(d). (Doc. No. 9 at 3). After receipt of the Motion, Defendants’ counsel contacted 11 Plaintiff’s counsel offering to pay the $180 service costs but refused to pay the $1,000 in 12 attorney’s fees associated with preparing and filing the Motion. (Doc. No. 13 at 2; Doc. No. 16 at 13 3). Unable to resolve the issue, Defendants filed an Opposition to the Motion and Plaintiff filed a 14 Reply. (Doc. No. 16 at 6). 15 APPLICABLE LAW AND ANALYSIS 16 A. Legal Standard 17 “An individual, corporation, or association that is subject to service . . . has a duty to avoid 18 unnecessary expenses of serving the summons.” Fed. R. Civ. P. 4(d). The Rule further provides: 19 If a defendant located within the United States fails, without good cause, to sign and return a waiver requested by a plaintiff located 20 within the United States, the court must impose on the defendant: 21 (a) The expenses later incurred in making service; and 22 (b) The reasonable expenses, including attorney’s fees, of any motion required to collect those service expenses. 23 24 Fed. R. Civ. P. 4(d)(2). See also Rollin v. Cook, 466 Fed. Appx. 665, 667 (9th Cir. 2012) (“Once 25 a plaintiff has sent a valid request for a waiver of service of process, the burden shifts to the 26 defendant to avoid imposing unnecessary costs on the plaintiff . . . Absent a showing of good 27 cause, a defendant who fails to execute a valid waiver ‘must’ pay the costs of formal service and 28 any costs, including reasonable attorney’s fees, of any motion ‘required’ to collect service 1 expenses.” Rule 4’s purpose “is ‘to eliminate the costs of service of a summons on many parties 2 and to foster cooperation among adversaries and counsel.’” Estate v. Darulis v. Garate, 401 F.3d 3 1060, 1063 (9th Cir. 2005) (quoting Fed. R. Civ. P. 4(d) Advisory Committee Note on 1993 4 Amendments). 5 B. Discussion 6 In Opposition to the Motion, Defendants explain that they had “attempted to arrange 7 representation for the lawsuit against them” but had not secured representation before the 30 days 8 to waive service had expired. (Doc. No. 13 at 2). However, Defendant do not contend that this 9 constituted good cause for their failure to return the waivers. Instead, Defendants raise two 10 objections: (1) the Motion was not “required” for recovery of service expenses, and (2) even if 11 required, the $1000 in attorney’s fees sought are excessive for a “page and a half motion.” (Doc. 12 No. 13 at 1). 13 1. Plaintiff’s Motion Was Required to Recover Service Expenses 14 It is uncontested that Defendants did not offer to pay Plaintiff’s service expenses until 15 after Plaintiff filed the instant Motion. Defendants cite Gold v. California Highway Patrol, 2020 16 WL 6562313 (N.D. Cal. 2020) for the proposition that a motion for service expenses is only 17 “required” under Rule 4 after “some effort by Plaintiff’s counsel” to avoid having to file such a 18 motion. (Doc. No. 13 at 3). In that case, the Court found that a motion for service expenses was 19 not “required” because defendants’ counsel had “made four statements acknowledging that 20 [d]efendants may have to pay service and expenses and explicitly offered to pay service 21 expenses” prior to plaintiff filing his motion. Gold, 2020 WL 6562313, at *3. 22 Defendants acknowledge that Gold is arguably distinguishable here, given that Defendants 23 did not offer to pay service expenses until after Plaintiff filed his Motion. (Doc. No. 13 at 3). 24 They nevertheless argue, relying on dicta in Gold, that Rule 4 implies a meet and confer 25 requirement before Plaintiff can file such a motion. (Id.). However, no such requirement can be 26 found in the plain text of the Rule, and federal courts have declined to imply such a requirement. 27 See, e.g., Rice v. Hamilton Davis Mental Health, Inc., 2023 WL 5185144, at *2 (S.D. Miss. Aug. 28 10, 2023); (rejecting argument that “attorney’s fees incurred in connection with the [] motion 1 should be denied,” where the “plaintiff failed to make a demand for payment of service expenses 2 before filing the [] motion,” because Rule 4(d)(2) “does not explicitly require a demand as a 3 prerequisite to recovery of fees” nor does it “implicitly impose such a requirement”); Brennan v. 4 Summer WWK LLC, 2021 WL 5033475, at *2 (N.D. Ga. Aug. 17, 2021) (“[the defendant] offers 5 no legal authority for his proposition that Plaintiff is required to make a demand upon a defendant 6 prior to filing a motion under Rule 4(d)(2)”). 7 The Court recognizes that this case was not assigned to District Judge Ana I. de Alba until 8 November 15, 2023, two days after Plaintiffs filed their Motion for Service Expenses. (See Doc. 9 No. 10). Admittedly, under Judge de Alba’s Standing Order in Civil Actions, “[p]rior to filing a 10 motion where the parties are represented by counsel, counsel shall engage in pre-filing meet and 11 confer to thoroughly discuss the substance of the contemplated motion and any potential 12 resolution.” E.D. Cal. S.O. J. de Alba at 2. See Bath v. Millennium Eng’g & Integration Co., 13 2023 WL 1315419, at *2 (E.D. Cal. Jan. 31, 2023). Judge de Alba’s Standing Order accords with 14 Federal Rule of Civil Procedure 1, which states that the Federal Rules “should be construed, 15 administered, and employed by the court and the parties to secure the just, speedy, and 16 inexpensive determination of every action and proceeding.” Fed. R. Civ. P.

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Bluebook (online)
Hulet v. County of Tuolumne, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hulet-v-county-of-tuolumne-caed-2024.