Peterson v. Subit

CourtDistrict Court, W.D. Washington
DecidedApril 2, 2025
Docket2:24-cv-00697
StatusUnknown

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

Bluebook
Peterson v. Subit, (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 DAVID W. PETERSON, CASE NO. C24-697 JNW 11 Plaintiff, ORDER GRANTING MOTION TO DISMISS 12 v. 13 MICHAEL C. SUBIT and FRANK FREED SUBIT & THOMAS LLP, 14 Defendants. 15 16 17 This matter comes before the Court on Defendants’ Motion to Dismiss. (Dkt. No. 11.) 18 Having reviewed the Motion, Plaintiff’s Response (Dkt. No. 13), the Reply (Dkt. No. 14), and all 19 supporting materials, the Court GRANTS the Motion and DISMISSES this action. 20 BACKGROUND 21 Plaintiff David Peterson pursues legal malpractice claims against Defendants Michael 22 Subit and the law firm Frank, Freed, Subit, & Thomas LLP. (Complaint (Dkt. No. 1).) Peterson 23 24 1 alleges that Subit failed to diligently represent him in an action Peterson commenced to obtain 2 withheld wages. (Id. at 5-6.) 3 Because Defendants’ Motion attacks the timeliness of Peterson’s complaint, the Court 4 reviews the allegations concerning the statute of limitations. Peterson alleges that “the injury

5 cannot have occurred before the court of appeals issued their order on June 28, 2021, because 6 until that date I was relying on Mr. Subit’s professional skill and experience to prevail in 7 prosecuting my case.” (Id. at 10.) Peterson alleges further that Subit’s “continuous representation 8 lasted until at least August 5, 2021” and that “[t]he Statute of Limitations [Wash. Rev. Code § 9 4.16.080(3)] would therefore expire on August 5, 2024, three years from the last date Mr. Subit 10 represented me, but no earlier than June 28, 2024, three years from the date the injury was 11 discovered.” (Id. at 10-11.) 12 Peterson filed the present lawsuit on May 17, 2024, and summons were issued on May 13 20, 2024. (Dkt. Nos. 1, 4.) Counsel for Defendants filed a notice of appearance on May 24, 2024, 14 which was done “without waiving objections as to improper service, jurisdiction and venue[.]”

15 (Dkt. No. 5.) Counsel also noted that he would accept service of “all further pleadings, notice, 16 documents, or other papers, exclusive of original process[.]” (Id.) In the Joint Status Report filed 17 by the Parties on July 29, 2024, Defendants again noted that they contested service. (Dkt. No. 9 18 at 6.) Defendants then filed their Motion to Dismiss, challenging the timeliness of the Complaint 19 on December 16, 2024. (Dkt. No. 11.) Although Defendants do not state Peterson failed to serve 20 them, they maintain in their motion that “to date, no Declarations of Service have been filed.” 21 (Mot. at 2.) 22 23

24 1 ANALYSIS 2 A. Legal Standard 3 Defendants move for dismissal under Federal Rule of Civil Procedure 12(b)(6). Rule 4 12(b)(6) permits the Court to dismiss a complaint for “failure to state a claim upon which relief

5 can be granted.” Fed. R. Civ. P. 12(b)(6). In ruling on a motion to dismiss, the Court must 6 construe the complaint in the light most favorable to the non-moving party and accept all 7 well-pleaded allegations of material fact as true. Livid Holdings Ltd. v. Salomon Smith Barney, 8 Inc., 416 F.3d 940, 946 (9th Cir. 2005); Wyler Summit P’ship v. Turner Broad. Sys., 135 F.3d 9 658, 661 (9th Cir. 1998). Dismissal is appropriate only where a complaint fails to allege “enough 10 facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 11 544, 570 (2007). A claim is plausible on its face “when the plaintiff pleads factual content that 12 allows the court to draw the reasonable inference that the defendant is liable for the misconduct 13 alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 14 In addition to Rule 12(b)(6), the Court considers Defendants’ Motion under Rule

15 12(b)(5), because it challenges the adequacy of service of process. “[S]ervice of summons is the 16 procedure by which a court having venue and jurisdiction of the subject matter of the suit asserts 17 jurisdiction over the person of the party served.” Miss. Publ’g Corp. v. Murphree, 326 U.S. 438, 18 444–445 (1946). “Before a federal court may exercise personal jurisdiction over a defendant, the 19 procedural requirement of service of summons must be satisfied.” Omni Capital Int'l, Ltd. v. 20 Rudolf Wolff & Co., Ltd., 484 U.S. 97, 104 (1987). If a defendant challenges service, the 21 plaintiff bears the burden of establishing that service was valid. See Brockmeyer v. May, 383 22 F.3d 798, 801 (9th Cir. 2004). If a district court finds service of process to be insufficient, it has 23

24 1 the discretion to either dismiss the claims against the moving defendant or to quash service. See 2 S.J. v. Issaquah Sch. Dist. No. 411, 470 F.3d 1288, 1293 (9th Cir. 2006). 3 B. Peterson’s Claims Are Untimely 4 The Court agrees with Defendants that Peterson’s claims are barred by the statute of

5 limitations and may not proceed. 6 To determine the proper statute of limitations, the Court must apply Washington law 7 because Peterson pursues claims under Washington law and the Court has federal jurisdiction 8 over the claims based on diversity jurisdiction. See Walker v. Armco Steel Corp., 446 U.S. 740, 9 752-53 (1980) (noting that “state service requirements which are an integral part of the state 10 statute of limitations should control in an action based on state law which is filed in federal court 11 under diversity jurisdiction”). Under Washington law, legal malpractice claims are subject to a 12 three year statute of limitations. RCW 4.16.080(3). Under the “continuous representation” 13 doctrine, “the statute of limitations [is tolled] until the end of an attorney's representation of a 14 client in the same matter in which the alleged malpractice occurred.” Janicki Logging & Const.

15 Co. v. Schwabe, Williamson & Wyatt, P.C., 109 Wn. App. 655, 661, 663-64 (2001). 16 Additionally, as to service of process, Washington law requires Plaintiff to complete service 17 within 90 days of the filing of the complaint. RCW 4.16.170. And Washington law makes clear 18 that if “service is not so made, the action shall be deemed to not have been commenced for 19 purposes of tolling the statute of limitations.” Id. “Washington courts have repeatedly held that 20 the filing of a complaint does not constitute the commencement of an action for the purposes of 21 tolling the statute of limitations.” O'Neill v. Farmers Ins. Co. of Washington, 124 Wn. App. 516, 22 523 (2004). 23

24 1 Peterson’s claims here are time barred because he failed to serve his complaint on 2 Defendants before the statute of limitations expired on August 5, 2024. As Peterson’s Complaint 3 demonstrates, Peterson was aware that he needed to commence this action by August 5, 2024. 4 While he did so, he did not effectuate service of process on Defendants—a point he does not

5 contest. Under Washington law, by having failed to complete service within 90 days of filing the 6 Complaint, the action must be deemed not to have commenced for purposes of tolling the statute 7 of limitations.

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Related

Mississippi Publishing Corp. v. Murphree
326 U.S. 438 (Supreme Court, 1946)
Walker v. Armco Steel Corp.
446 U.S. 740 (Supreme Court, 1980)
Watters v. Wachovia Bank, N. A.
550 U.S. 1 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Janicki Logging & Construction Co. v. Schwabe, Williamson & Wyatt, P.C.
109 Wash. App. 655 (Court of Appeals of Washington, 2001)
O'Neill v. Farmers Insurance
125 P.3d 134 (Court of Appeals of Washington, 2004)
United States v. Haversat
22 F.3d 790 (Eighth Circuit, 1994)
Livid Holdings Ltd. v. Salomon Smith Barney, Inc.
416 F.3d 940 (Ninth Circuit, 2005)

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Peterson v. Subit, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peterson-v-subit-wawd-2025.