Michael A. Doyle v. P YMCA of New Hampshire

2021 DNH 118
CourtDistrict Court, D. New Hampshire
DecidedJuly 26, 2021
Docket21-cv-112-SE
StatusPublished
Cited by1 cases

This text of 2021 DNH 118 (Michael A. Doyle v. P YMCA of New Hampshire) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael A. Doyle v. P YMCA of New Hampshire, 2021 DNH 118 (D.N.H. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Michael A. Doyle

v. Civil No. 21-cv-112-LM Opinion No. 2021 DNH 118 P YMCA of New Hampshire

ORDER

Pro se plaintiff Michael A. Doyle brings this action against defendant The

Granite Young Men’s Christian Association1 (“Granite YMCA”), alleging that

defendant violated his rights under the Americans With Disabilities Act (“the

ADA”), 42 U.S.C. § 12181 et seq. Defendant moves to dismiss (doc. no. 6) on the

bases of insufficient process and insufficient service of process. See Fed. R. Civ. P.

12(b)(4), (5). For the following reasons, defendant’s motion is denied.

BACKGROUND

The following background facts are drawn from the complaint. Plaintiff

suffers from rheumatoid arthritis in his knees, ankles, and hips. As a result,

plaintiff has intermittent walking difficulties and must use handicap parking

spaces. Plaintiff also has difficulty getting out of chairs that are low to the ground.

Defendant owns and operates a facility in Portsmouth, New Hampshire,

known as the YMCA of the Seacoast (“Seacoast YMCA”). Seacoast YMCA operates

an outdoor pool. Plaintiff is or was a member of this facility and used the pool.

1 The complaint misnames defendant as “YMCA of New Hampshire.” However, defendant did not permit plaintiff to park in handicap parking spaces

close to the pool entrance. In addition, the armchairs defendant provided for the

pool area were too low to the ground for plaintiff to use. This forced plaintiff to

carry his own beach chair to the pool area.

Plaintiff, proceeding pro se, brought this action against “YMCA of New

Hampshire” in February 2021. Plaintiff alleges in his complaint that YMCA of New

Hampshire’s actions violate the ADA. He seeks declaratory and injunctive relief.

On April 5, 2021, plaintiff filed a motion requesting additional time to

complete service of process.2 See doc. no. 2. Plaintiff included a copy of a summons

with his motion. The summons includes a case caption identifying the defendant as

YMCA of New Hampshire. It does not contain the clerk of court’s signature or the

court’s seal. In an accompanying certificate of service dated April 1, 2021, plaintiff

certified under penalty of perjury that he caused the summons to be served “upon

Defendant’s management, David Ports, President/CEO at the defendant’s address of

15 North State St., Concord, NH 03301.” Id. at 4.

On April 23, plaintiff filed a return of service with the court. See doc. no. 3.

As with the summons accompanying plaintiff’s April 5 motion, the summons

includes a case caption identifying the defendant as YMCA of New Hampshire and

lacks the court’s seal as well as the clerk’s signature. The certified mail receipt

accompanying the return indicates that the summons was sent to “YMCA of N.H.”

at an address of 15 North State Street in Concord, New Hampshire.

2 The court granted this motion in an endorsed order on April 13.

2 On June 14, defendant appeared through counsel and moved for additional

time to respond to the complaint. See doc. no. 4. Defendant stated in this motion

that it owned and operated Seacoast YMCA and it appeared to be the proper

defendant in this action, but that it had been misnamed in the complaint as YMCA

of New Hampshire, a non-entity. Defendant stated that it became aware of

plaintiff’s complaint after it learned of plaintiff’s attempt to effect service of process

at 15 North State Street in Concord, the address of a YMCA facility that defendant

did not operate. The court granted defendant’s motion in an endorsed order.

On June 28, plaintiff filed an additional return of service with the court. See

doc. no. 5. The summons included with the return contained a case caption

identifying the defendant as YMCA of New Hampshire. The summons failed to

include the clerk’s signature or the court’s seal. The certificate of service included

with the return indicates that Deputy Sheriff Michael E. Chavez delivered the

summons to “Kelly McKenna, Executive Director, YMCA of New Hampshire” at 550

Peverly Hill Road in Portsmouth, New Hampshire.

On July 1, defendant filed the instant motion to dismiss for insufficient

process and insufficient service of process.3 See doc. no. 6.

3 On July 12, plaintiff filed another motion to extend time for service. See doc. no. 9. He filed an additional return of service that same day. See doc. no. 8. The case caption on the summons once again identifies the defendant as YMCA of New Hampshire. The summons does, however, include the court’s seal and the clerk’s signature. The return also includes a blank proof of service form.

3 DISCUSSION

Defendant acknowledges that it is the proper defendant in this action and

that it has received actual notice of plaintiff’s complaint. Doc. no. 6 at 1, 6.

Moreover, the court granted defendant’s request for additional time to object or

respond to plaintiff’s complaint. Defendant now moves to dismiss for insufficient

process under Rule 12(b)(4) and insufficient service of process under Rule 12(b)(5).

I. Legal Standard

A defendant may challenge the sufficiency of process under Rule 12(b)(4) and

may challenge the manner in which process was served under Rule 12(b)(5). See 5B

Arthur R. Miller et al., Federal Practice and Procedure: Civil § 1353 (3d ed.). A

challenge to the sufficiency of process “concerns the form of the process rather than

the manner or method of its service.” Girard v. Dodd, Civ. No. 2:16-CV-165-DBH,

2016 WL 4734373, at *1 (D. Me. Sept. 9, 2016). “Thus, a motion under Rule 12(b)(4)

in effect challenges the content of the summons and whether it complied with

Federal Rule of Civil Procedure 4(a) and (b).” Id. By contrast, a “Rule 12(b)(5)

motion is the proper vehicle for challenging the mode of delivery or the lack of

delivery of the summons and complaint.” Miller et al., supra.

II. Insufficient Process

Rule 4(a)(1) requires the summons to “name . . . the parties,” “be directed to

the defendant,” and bear the clerk’s signature and the court’s seal. Fed. R. Civ. P.

4(a)(1). Defendant argues that both the April and June returns fail to demonstrate

that defendant received process that complied with these requirements. Defendant

4 is correct that these summonses misname defendant in the case caption and do not

include the clerk’s signature or the court’s seal. However, a Rule 12(b)(4) motion to

dismiss “will be granted only when the defect is prejudicial to the defendant.”

Miller et al., supra. Defendant does not argue that it has been prejudiced by these

defects in process. And, given that defendant received actual notice of the

complaint and an extension of time to respond thereto, the court fails to see how

any of these defects could be prejudicial. Accordingly, defendant’s motion to dismiss

is denied insofar as it is based on insufficient process.

That said, “the court lacks discretion to ignore deficiencies in process.”

Wilson v. Brock, No. Civ. 01-284-JD, 2002 WL 1676287, at *3 (D.N.H. July 18, 2002)

(citing Fed. R. Civ. P. 4(m)); see also Omni Capital Int’l v.

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Doyle v. YMCA of New Hampshire
D. New Hampshire, 2021

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2021 DNH 118, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-a-doyle-v-p-ymca-of-new-hampshire-nhd-2021.