National Legal and Policy Center v. Berkshire Hathaway Inc.

District Court, D. Nebraska·Decided August 8, 2025·No. 8:24-cv-00162·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

NATIONAL LEGAL POLICY CENTER, PETER T. FLAHERTY, and JAMES “JAMIE” TOVAR, 8:24CV162

Plaintiffs, MEMORANDUM AND ORDER ON vs. DEFENDANT DAN CLARK’S MOTION TO DISMISS BERKSHIRE HATHAWAY, INC. WARREN BUFFETT, CHRIS THOMPSON, and DAN CLARK,

Defendants.

Plaintiffs National Legal Policy Center (NLPC), Peter T. Flaherty, and James Tovar (collectively, Plaintiffs) bring nine claims against Defendants Berkshire Hathaway, Warren Buffett, Chris Thompson, and Dan Clark. Filing 55 at 1. The Court presently considers Defendant Clark’s Motion to Dismiss the claims against him for failure to state a claim upon which relief can be granted under Federal Rule of Civil Procedure 12(b)(6). Filing 69 at 1. Plaintiffs did not file an opposition to this Motion. For the following reasons, the Court grants Clark’s Motion, the claims against defendant Thompson are dismissed without prejudice sua sponte for failure to timely serve that Defendant, judgment is entered in favor of the other Defendants, and this case is dismissed in its entirety. I. INTRODUCTION The Amended Complaint in this case makes factual allegations identical to those in the Original Complaint, with the exception of the John Does’ identities. As such, the Court declines to recite the entire factual and procedural background set out in Filing 36. See Nat’l Legal Policy Ctr v. Berkshire Hathaway Inc., No. 8:24CV162, 2024 WL 4605410 (D. Neb. Oct. 29, 2024) 1 (memorandum and order on Berkshire Hathaway’s and Warren Buffett’s Motion to Dismiss and Motion to Strike). Therefore, the Court focuses its discussion on the history subsequent to the Amended Complaint and the Motion to Dismiss Order set out in Filing 36. However, for context, the Court will also summarize the disposition of the prior Motion to Dismiss. A. The Prior Motion to Dismiss

In June 2024—before the John Doe Defendants had been identified—Defendants Berkshire Hathaway and Warren Buffett filed a Motion to Dismiss all claims filed against them. Filing 20. On October 29, 2024, the Court granted the Motion to Dismiss1 because of Flaherty’s self-alleged trespass and Plaintiffs’ failure to allege sufficient factual matter in the pleadings to plausibly state their claims. Filing 36 at 25. In the previous Motion to Dismiss Order, the Court noted that Federal Rule of Civil Procedure 4(m) requires Plaintiffs to serve defendants, named and unnamed, within 90 days after filing their complaint. Filing 36 at 24; Fed. R. Civ. P. 4(m). At the time of the Order, Plaintiffs had yet to name or provide a service of summons and complaint on the John Doe Defendants, then identified only as unnamed security guards. Filing 36 at 24. Plaintiffs had also failed to file a

motion for an extension of time to permit discovery of the John Doe Defendants’ identities. Filing 36 at 24. Accordingly, the Court ordered that Plaintiffs claims against “John Does 1 and 2” be dismissed within seven days of the Order, absent a motion for extension of time demonstrating good cause. Filing 36 at 25.

1 The Court also granted the Defendant’s Motion to Strike the Declaration of Flaherty. Filing 36 at 25. 2 B. Subsequent Proceedings In response to this Order, Plaintiffs sought an extension of time to serve the “Doe Defendants.” Filing 55 at 2. The Court granted the Motion and ordered Plaintiffs to perfect service on or before November 27, 2024. Filing 55 at 2. Plaintiffs filed an Amended Complaint which named Chris Thompson and Dan Clark as defendants and requested summonses for them. Filing

55 at 2. The Amended Complaint was then stricken for being filed without leave. Filing 55 at 2. However, prior to the Order striking the Amended Complaint, Plaintiffs sought an extension to serve Chris Thompson and Dan Clark (collectively, Security Guard Defendants). Filing 55 at 2. The Court denied Plaintiffs’ motion as moot because after the Amended Complaint was stricken the defendants named in Plaintiffs’ extension were not named in the operative complaint. Filing 55 at 2. Plaintiffs next tried to appeal the October 29, 2024, Order dismissing the claims against Berkshire Hathaway and Warren Buffett, which the Eighth Circuit Court of Appeals dismissed for lack of jurisdiction. Filing 55 at 2. The magistrate judge issued an order to show cause why the case should not be dismissed for want of prosecution, and in response Plaintiffs filed a motion for

leave to file an Amended Complaint. Filing 55 at 2. The magistrate judge granted leave to amend and sua sponte extended Plaintiffs’ deadline to serve the Security Guard Defendants. Filing 55 at 2–3. Since the proposed Amended Complaint is identical to the first, it realleges the claims against Berkshire Hathaway and Warren Buffett that were already dismissed by the Court. Filing 55 at 3. The magistrate judge recommended that the Court dismiss the claims against Berkshire Hathaway and Warren Buffett for the reasons articulated in the Court’s previous order. Filing 55 at 3; Filing 36. On March 11, 2025, the Court accepted this recommendation and ordered that the 3 claims against defendants Berkshire Hathaway and Warren Buffett again be dismissed in their entirety. Filing 63 at 3. On April 16, 2025, Clark filed a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6). Filing 69 at 1. Specifically, Clark seeks to dismiss Flaherty’s and Tovar’s separate claims against him for assault, battery, and false imprisonment, as well as the NLPC’s

and Flaherty’s promissory estoppel claim. Filing 70 at 13–14. Plaintiffs did not file any timely opposition to Clark’s Motion. I. ANALYSIS A. Preliminary Matters The Court notes that Plaintiffs’ original Complaint and Amended Complaint raise jurisdictional concerns. Filing 36 at 5. Both the original Complaint and the Amended Complaint allege that the Court has jurisdiction over this matter “pursuant to 28 U.S.C. § 1332(d) because: (a) there is a complete diversity of citizenship between Plaintiffs and Defendants; and (b) the amount in controversy exceeds $75,000 exclusive of costs and interests.” Filing 56 at 1. In its prior ruling, Filing 36, the Court assumed Plaintiffs intended to invoke the Court’s original diversity jurisdiction pursuant to § 1332(a)(1), rather than § 1332(d), which is a provision of the Class

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National Legal and Policy Center v. Berkshire Hathaway Inc., (D. Neb. 2025).

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