Rangel v. Doe

District Court, S.D. Texas·Decided April 11, 2025·No. 4:24-cv-00684·Unknown

Opinion

UNITED STATES DISTRICT COURT April 11, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION JESUS ANTONIO RANGEL, § § Plaintiff. § § V. § CIVIL ACTION NO. 4:24-cv-00684 § JOHN OR JANE DOE, et al., § § Defendants. §

OPINION AND ORDER On February 8, 2024, Plaintiff Jesus Antonio Rangel instituted a negligence action in state court against Defendant Werner Enterprises, Inc. to recover for the injuries he sustained as a result of an April 14, 2022 hit-and-run by a tractor-trailer driver. Werner is the owner of the trailer that was being pulled by the tractor that hit Rangel. In addition to Werner, Rangel also named the unidentified driver of the vehicle that hit him as Defendant Doe. On February 26, 2024, Werner removed this action to this court on the basis of federal diversity jurisdiction. On July 25, 2024, I entered a Docket Control Order to govern the deadlines in this case. Relevant here, I set a deadline of September 6, 2024, to add new parties. See Dkt. 19 at 1. On February 3, 2025, Werner timely filed a motion for summary judgment. Dkt. 29. Rangel’s response to that motion, if any, was due on February 24, 2025. On February 24, 2025, Rangel did not file a response to Werner’s motion for summary judgment. Rather, Rangel filed a First Amended Complaint, purporting to substitute 3RM Services, LLC—the company that Werner contracted with to transport Werner’s trailer, and that hired the driver of the tractor that was pulling Werner’s trailer at the time of the hit-and-run—as a Doe defendant. See Dkt. 32 at 1. Rangel did not request leave of court to add a new party. In his First Amended Complaint, Rangel also purports to add four new causes of action against Werner: (1) fraudulent concealment of material facts and equitable estoppel, (2) negligent selection and hiring of 3RM, (3) non-delegable duty, and (4) joint enterprise. On February 25, 2025, Rangel filed Plaintiff’s Motion for Continuance, Objections to Defendant Werner’s Summary Judgment Evidence, and Response to Defendant Werner Enterprises, Inc.[’s] Motion for Summary Judgment. Dkt. 33. On March 7, 2025, I entered an Opinion and Order (1) finding Rangel’s First Amended Complaint (Dkt. 32) untimely and striking it from the record; (2) denying Rangel’s Motion for Continuance (Dkt. 33); and (3) granting Werner’s Motion for Summary Judgment (Dkt. 29). See Dkt. 35 at 9. I entered a final judgment in this case on March 7, 2025. See Dkt. 36. On April 4, 2025, Rangel filed a Motion to Dismiss for Lack of Subject Matter Jurisdiction and Remand to State Court or in the Alternative Motion for Leave to File Plaintiff’s First Amended Complaint or in the Alternative, Motion for New Trial. Dkt. 37. That motion is denied to the extent that Rangel believes 3RM, an ostensibly nondiverse defendant,1 may be substituted or added as a party at this late stage. But the motion is granted insofar as Rangel’s First Amended Complaint was indeed timely filed. In the interest of judicial economy, I will deny Werner’s original summary judgment motion without prejudice so that we can address all the claims raised in the First Amended Complaint in one fell swoop.2

1 Rangel alleges that “3RM Services LLC is a company based in Texas and does business in Texas.” Dkt. 32 at 2. These allegations are irrelevant to establishing an LLC’s citizenship. See Megalomedia Inc. v. Phila. Indem. Ins. Co., 115 F.4th 657, 660 (5th Cir. 2024) (remanding a case that had proceeded through trial to the district court because diversity of citizenship was not evident in the court’s record). The citizenship of a limited liability entity is determined by the citizenship of its members. See Harvey v. Grey Wolf Drilling Co., 542 F.3d 1077, 1080 (5th Cir. 2008). When members of a limited liability entity are themselves entities or associations, citizenship must be traced through however many layers of members there are until arriving at the entity that is not a limited liability entity and identifying its citizenship status. See Mullins v. TestAmerica, Inc., 564 F.3d 386, 397–98 (5th Cir. 2009). Under this standard, Rangel has not alleged 3RM’s citizenship. Even so, I will assume without deciding that, if added, 3RM would destroy diversity jurisdiction. As discussed below, 3RM cannot be added to this litigation. 2 I will not penalize Rangel for timely filing an amended pleading simply because Werner filed a motion for summary judgment more than two months in advance of the dispositive RANGEL’S ATTEMPT TO ADD 3RM AS A PARTY I previously found that Rangel’s First Amended Complaint, filed on Monday, February 24, 2025, was untimely. See Dkt. 35 at 2. Yet, as Rangel points out, the February 23, 2025 deadline to amend pleadings fell on a Sunday, which means the deadline ran through the following Monday, making Rangel’s First Amended Complaint timely. See Dkt. 37 at 2–3. That Rangel’s First Amended Complaint was timely does not, however, make Rangel’s attempt to add a new party timely. To the contrary, Rangel’s attempt to add a new party is both untimely and futile. As stated in the Docket Control Order, “[a]fter expiration of [the deadline to add new parties], a party seeking to add a new party must file a motion for leave demonstrating both good cause and excusable neglect in accordance with Fed. R. Civ. P. 6(b)(1)(B).” Dkt. 19 at 1. Rangel has filed no such motion. “[F]ailing to request leave from the court when leave is required makes a pleading more than technically deficient. The failure to obtain leave results in an amended complaint having no legal effect.” U.S. ex rel. Mathews v. HealthSouth Corp., 332 F.3d 293, 296 (5th Cir. 2003); see also U.S. ex rel. Willard v. Humana Health Plan of Tex. Inc., 336 F.3d 375, 387 (5th Cir. 2003) (“A party who neglects to ask the district court for leave to amend cannot expect to receive such a dispensation from the court of appeals.”). Accordingly, while Rangel’s First Amended Complaint is timely, his attempt to add 3RM is a nullity. Even if I were to consider Rangel’s motion for continuance as a motion for leave, I would still deny his request to add 3RM to this litigation. When a deadline has passed, I “may, for good cause, extend the time . . . on motion made after the time has expired if the party failed to act because of excusable neglect.” FED. R. CIV. P. 6(b)(1)(B). The Supreme Court has articulated four non-exhaustive factors to consider when determining whether neglect was excusable: (1) “the danger of

motion deadline. The Docket Control Order “put both parties on notice of potential amendments.” Edwards v. Tristar Prods., Inc., No. 1:18-cv-27, 2019 WL 1028526, at *2 (N.D. Miss. Mar. 4, 2019) (denying defendant’s motions for summary judgment, filed before the extended deadline to amend pleadings, without prejudice as moot). prejudice” to the opposing party, (2) “the length of the delay and its potential impact on judicial proceedings,” (3) “the reason for the delay, including whether it was within the reasonable control of the movant,” and (4) “whether the movant acted in good faith.” Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd., 507 U.S. 380, 395 (1993); see also L.A. Pub. Ins. Adjusters, Inc. v. Nelson, 17 F.4th 521, 525 (5th Cir.

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