(PS) Rhuma v. State of Libya

District Court, E.D. California·Decided September 8, 2023·No. 2:20-cv-02366·Unknown

Opinion

TAHER RHUMA, et al., No. 2:20-cv-02366-DJC-AC-PS Plaintiffs, v. ORDER STATE OF LIBYA, Defendant.

Plaintiffs proceed in this action in pro per. The matter was referred to a United

States Magistrate Judge pursuant to Local Rule 302(c)(21).

On March 29, 2023, the Magistrate Judge filed findings and recommendations

herein which were served on the parties and which contained notice that any

objections to the findings and recommendations were to be filed within twenty one

days. (ECF No. 35 .) The Magistrate Judge recommends that this action be dismissed as to Plaintiff Mohamad Laham without prejudice for failure to prosecute and follow court orders, and as to Plaintiffs Taher Rhuma and Khadija Kanoun with prejudice for lack of jurisdiction based on res judicata. ( at 17.) Plaintiffs have filed objections to the findings and recommendations. (ECF No. 37.)

////

////

Under the Federal Magistrates Act, the court may “accept, reject, or modify, in

whole or in part, the findings or recommendations made by the magistrate.” 28 U.S.C.

§ 636(b)(1). If a party objects to a magistrate judge's findings and recommendations,

“the court shall make a de novo determination of those portions of the report or

specified proposed findings or recommendations to which objection is made.” ;

Fed. R. Civ. P. 72(b)(3). If no party objects, there is no prescribed standard of review.

, 328 F.3d 1114, 1121 (9th Cir. 2003) (en banc)

(holding that the court must review de novo magistrate judge's findings and

recommendations if objection is made, “but not otherwise”).

As Plaintiffs have filed objections, the Court will apply a de novo standard of

review. For the reasons set forth below, the Court declines to adopt the Magistrate

Judge’s findings and recommendations.

I. Failure to Prosecute and Follow Court Orders

First, the Magistrate Judge’s finding that Plaintiffs failed to follow court orders is

not entirely supported by the record.

Section 1608(a) governs service of process on “a foreign state or political

subdivision of a foreign state.” 28 U.S.C. § 1608(a); Fed. R. Civ. P. 4(j)(1). In particular,

it sets out in hierarchical order four methods by which “[s]ervice . . . shall be made.”

28 U.S.C. § 1608(a). The Magistrate Judge previously found that service could not be

made under section 1608(a)(1) or 1608(a)(2). (ECF 21 at 5–6.). Thus, Plaintiffs were

ordered to provide service documents along with a letter of request for service to the

Clerk of Court that included the “name(s), title(s) and address(es) of the person(s) to

be served” so that service could occur under section 1608(a)(3). ( at 6–7.) Section

1608(a)(3) requires that service be sent “by any form of mail requiring a signed

receipt, to be addressed and dispatched by the clerk of the court to the head of the

ministry of foreign affairs of the foreign state concerned.” 28 U.S.C. § 1608(a)(3).

Plaintiffs provided the required documents, (ECF No. 25,) and the Clerk’s Office mailed them to Libya via DHL on June 8, 2022, (ECF No. 26.) On July 25, 2022,

Plaintiffs filed proof of service indicating that the summons and complaint had been

delivered to the Libyan Ministry of Foreign Affairs (the “Ministry”), Ash Shatt St., Tripoli,

Libya on June 19, 2022. (ECF No. 27.) Despite delivery of the service packet,

Defendant has not appeared in this action to-date. (ECF No. 35 at 4.)

The Magistrate Judge found that Plaintiffs failed to follow the court’s orders

because “[t]he letter that plaintiff provided did not specify by name and title any

person to be served, but simply identified the Ministry of Foreign Affairs in Tripoli as

the intended recipient.” (ECF No. 35 at 13.) However, in Plaintiffs’ letter to the Clerk

of Court, they specified that “[t]he following documents . . . must be addressed to the

Head of the Libyan Ministry of Foreign affairs and international cooperations, Najla

Mohammed El Mangoush.” (ECF No. 25 at 1.) Minister El Mangoush was the Minister

of Foreign Affairs (the “Minister”) when Plaintiffs provided the service packet to the

Clerk of Court. Further, the waybill on the DHL envelope the service documents were

sent in states “ATTN: MINISTER NAJ.” (ECF No. 25-11.) “A letter or package is

‘addressed’ to an intended recipient when his or her name and ‘address’ is placed on

the outside of the item to be sent.” , 139 S. Ct. 1408,

1506 (2019). Here, the package included at least a portion of the Minister’s name,

along with the address for the Ministry; while it would have been preferrable to

include the Minister’s full name, this shows that Plaintiffs were attempting to comply

with the court’s directions. Indeed, it appears the address used by Plaintiffs was

correct as the DHL proof of delivery shows the service packet was delivered to the

Ministry, (ECF No. 27,) although the Court agrees with the Magistrate Judge that this

does not clarify if the service packet was given to the Minister herself as the package

was signed for by an unknown individual named “Hamza,” (ECF No. 35 at 15.) Finally,

while the Magistrate Judge is correct that the summonses were directed generally to

the State of Libya, without reference by name or title to any specific Libyan official

authorized to receive service, (ECF No. 35 at 13,) the Magistrate Judge did not specify this requirement previously, ( ECF No. 21.) Thus, Plaintiffs largely complied with

the Magistrate Judge’s directions.

While the Court finds that Plaintiffs substantially complied with the Magistrate

Judge’s directions regarding service, it also concerned that Plaintiffs have failed to

diligently advance this matter despite many admonitions to do so. The Magistrate

Judge has correctly observed that this case cannot be allowed to languish on this

Court’s docket. Thus, this Court will grant Plaintiffs one final opportunity to properly

serve Defendant and take appropriate steps contemplated under the Federal Rules of

Civil Procedure to prosecute this matter once service has been completed, or this

matter will be dismissed.

Because Plaintiffs have attempted service under section 1608(a)(3) and service

failed, Plaintiffs may attempt service under section 1608(a)(4).1 28 U.S.C.

§ 1608(a)(4). Service is accomplished

by sending two copies of the summons and complaint and a notice of suit, together with a translation of each into the

official language of the foreign state, by any form of mail requiring a signed receipt, to be addressed and dispatched

by the clerk of the court to the Secretary of State in Washington, District of Columbia, to the attention of the

Director of Special Consular Services—and the Secretary shall transmit one copy of the papers through diplomatic

channels to the foreign state and shall send to the clerk of the court a certified copy of the diplomatic note indicating

Free access — add to your briefcase to read the full text and ask questions with AI

(PS) Rhuma v. State of Libya, (E.D. Cal. 2023).

(PS) Rhuma v. State of Libya ((PS) Rhuma v. State of Libya) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Parklane Hosiery Co. v. Shore
439 U.S. 322 (Supreme Court, 1979)
Arizona v. California
530 U.S. 392 (Supreme Court, 2000)
Roderick Courtney Mann v. American Airlines
324 F.3d 1088 (Ninth Circuit, 2003)