Lietz v. Drug Enforcement Administration

CourtDistrict Court, D. Idaho
DecidedJune 30, 2023
Docket1:22-cv-00209
StatusUnknown

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

Bluebook
Lietz v. Drug Enforcement Administration, (D. Idaho 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

PAUL LIETZ, Case No. 1:22-cv-00209-BLW Plaintiff, MEMORANDUM DECISION AND v. ORDER

DRUG ENFORCEMENT ADMINISTRATION, et al.,

Defendants.

INTRODUCTION Before the Court are two motions for entry of default filed by Plaintiff Paul Lietz. Dkts. 39 & 42. For the reasons explained below, both motions will be denied. BACKGROUND Plaintiff Paul Lietz filed this lawsuit after state and federal law enforcement executed a search warrant on his home. He claims that the officers acted unlawfully during the search and subsequent detentions and interrogations. Dkt. 1. His complaint, filed May 12, 2022, advances twenty-nine claims against twenty named defendants. See id. Two groups of law enforcement authorities make up the defendants in this case: local law enforcement (“Local Defendants”)1 and federal law enforcement (“Federal Defendants”)2. After partially prevailing on their motions to dismiss, the

Local Defendants stipulated to a settlement and Lietz voluntarily dismissed his claims against them with prejudice. Dkt. 53. What remains of this action, then, are Lietz’s claims against the Federal Defendants.

Unlike the Local Defendants, the Federal Defendants have not responded to Lietz’s complaint. For that reason, Lietz now asks the Court to enter default against them under Federal Rule of Civil Procedure 55(a). As the defendants explain, however, their time to respond to the complaint has not even started to run because

Lietz has not properly served process under Federal Rule of Civil Procedure 4(i). Lietz’s two motions for entry of default are fully briefed and properly before the Court. As explained below, the Court will deny both motions but will extend

the time for Lietz to serve the Federal Defendants.3

1 Local Defendants include the City of Nampa, Nampa Police Department, Michael Coronado, Angel Calderon, Canyon County, the Canyon County Sheriff’s Department, Cary Salazar, Justin Wright, Shawn Weigelt, Shawn Parker, Ken Nicodemus, Isaac Hodges, Michael Armstrong, Trevor Heim, Chad Bingham, and Bryce Moor. 2 Federal Defendants include the Drug Enforcement Administration (DEA), Special Agent Colin Fine, Special Agent David Clyde, Special Agent Dustin Bloxham, and Special Agent Brandon Poggi. 3 Although Lietz filed two separate motions for entry of default (one for Defendant (Continued) LEGAL STANDARD 1. Entry of Default

In federal court, a plaintiff may obtain a default against a defendant who fails to timely respond to a complaint. FED. R. CIV. P. 55(a). Then, once a default is entered, the plaintiff may seek entry of default judgment (1) from the Clerk of Court if the sum is certain or can be made certain by computation or (2) upon

application to the Court in all other cases. FED. R. CIV. P. 55(b)(1) & (2). 2. Service of Process To initiate a lawsuit, a plaintiff must serve a summons and copy of the

complaint on the defendant. FED. R. CIV. P. 4(c)(1). The proper method of service depends on who the defendant is and where the defendant is located. To sue the United States, a federal agency, or a federal employee, a plaintiff must comply with the special service-of-process rules found in Rule 4(i) of the Federal Rules of

Civil Procedure. To sue a federal agency or a federal employee in her official capacity, a plaintiff must both (1) satisfy the requirements for serving the United States and

(2) send a summons and copy of the complaint by registered or certified mail to the

Dustin Bloxham and one for the other Federal Defendants), both suffer the same infirmity. The Court will therefore address the motions together. specific agency or employee being sued. FED. R. CIV. P. 4(i)(2). There are three requirements for serving the United States. Id. First, the plaintiff must either (i)

personally deliver a summons and a copy of the complaint to the United States Attorney in the district where the action is brought, or (ii) send a copy of each by registered or certified mail to the U.S. Attorney’s civil-process clerk in that district.

FED. R. CIV. P. 4(i)(1)(A)(i-ii). 4 Second, the plaintiff must send a summons and copy of the complaint to the United States Attorney General in Washington, D.C., by registered or certified mail. FED. R. CIV. P. 4(i)(1)(B). And third, if the lawsuit involves a non-party federal agency or officer, the plaintiff must send a summons

and copy of the complaint to that entity or person by registered or certified mail. FED. R. CIV. P. 4(i)(1)(C). The service-of-process requirements for suing a federal employee in her

personal capacity are slightly different. A plaintiff must (1) satisfy the above-listed requirements for serving the United States and (2) serve the employee in compliance with Rule 4(e), (f), or (g), whichever subsection is applicable. FED. R.

4 Note, however, that under Federal Rule of Civil Procedure 4(c)(2), only a non-party may carry out service of process. In the context of Rule 4(i)(1)(A), that means a plaintiff must have a non-party either personally deliver or send the summons and complaint to the necessary recipients. That is to say, the plaintiff himself or herself cannot do the delivering or sending. See Guthery v. U.S., 507 F.Supp.2d 111, 115 (D.C. Cir. 2007). CIV. P. 4(i)(3). Once a defendant has been served with a summons and complaint, her time

to respond begins to run. Under Rule 12(a)(2), the United States, its agencies, and its employees who are sued in their official capacities must respond “within 60 days after service on the United States attorney.” FED. R. CIV. P. 12(a)(2). Federal

employees who are sued in their personal capacities must respond “within 60 days after service on the officer or employee or service on the United States attorney, whichever is later.” FED. R. CIV. P. 12(a)(3). ANALYSIS

1. Lietz has not properly served the Federal Defendants and therefore is not entitled to entry of default. The key question here is whether Lietz has properly served the Federal Defendants. If he has, their 60-day response window may have closed, and default may be appropriate. If he has not, the time for those defendants to respond has not started and default is inappropriate. The answer hinges on whether Lietz satisfied the first two requirements for

service under Rule 4(i)(1); that is, whether he sent a summons and copy of the complaint by registered or certified mail to the U.S. Attorney’s civil-process clerk in the District of Idaho and to the U.S. Attorney General in Washington, D.C. See

FED. R. CIV. P. 4(i)(1)(A)(i–ii). Doing so is a prerequisite to serving the United States, and serving the United States is a prerequisite to serving federal agencies and federal employees (whether in their personal or official capacities). A failure to

take either step therefore precludes a plaintiff from properly serving any federal agency or employee.5 Lietz sent a summons and copy of the complaint by Federal Express

(“FedEx”) to the U.S. Attorney General’s Office in Washington, D.C., and to the U.S. Attorney’s Office in Boise, Idaho. See Ex. A, Dkt. 39-2. But, as the Federal Defendants note, in the Ninth Circuit, FedEx does not count as “registered or certified mail” for purposes of Rule 4. Magnuson v. Video Yesteryear, 85 F.3d

1424, 1431 (9th Cir. 1996).6 Lietz protests that distinguishing between delivery by FedEx and registered

5 For this reason, it is not enough that the U.S. Marshals personally served SA Dustin Bloxham.

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