Richard-Edward Lane v. Medford Oregon City Attorney’s Office and Jackson County District Attorney’s Office

CourtDistrict Court, D. Oregon
DecidedOctober 29, 2025
Docket1:25-cv-00559
StatusUnknown

This text of Richard-Edward Lane v. Medford Oregon City Attorney’s Office and Jackson County District Attorney’s Office (Richard-Edward Lane v. Medford Oregon City Attorney’s Office and Jackson County District Attorney’s Office) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard-Edward Lane v. Medford Oregon City Attorney’s Office and Jackson County District Attorney’s Office, (D. Or. 2025).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

MEDFORD DIVISION

RICHARD-EDWARD LANE, Case No. 1:25-cv-00559-MTK

Plaintiff, OPINION AND ORDER v. MEDFORD OREGON CITY ATTORNEY’S OFFICE and JACKSON COUNTY DISTRICT ATTORNEY’S OFFICE, Defendants.

KASUBHAI, United States District Judge: This matter comes before the Court on the Motions to Dismiss of Defendants Medford City Attorney’s Office and Jackson County District Attorney’s Office, ECF Nos. 22, 26. For the reasons that follow, Defendants’ Motions are granted. BACKGROUND On January 17, 2025, Plaintiff filed a Complaint against the Medford Police Department, four officers of the Medford Police Department, and Senior Assistant Medford City Attorney Garret Ramsey and asserted claims for violations of various constitutional rights, UCC 1-308, and several criminal statutes related to a September 15, 2024 traffic stop and arrest for driving under the influence. Case No. 1:25-cv-00093-MC, ECF No. 1. That matter was assigned to United States District Judge Michael McShane. On March 12, 2025, Judge McShane dismissed the matter on the basis that Plaintiff’s Complaint presented claims that asked the Court to interfere with ongoing state proceedings for criminal charges stemming from Plaintiff’s arrest.1 On April 7, 2025, Plaintiff filed a Complaint in this Court against the Medford City

Attorney’s Office (“MCAO”) and the Jackson County District Attorney’s Office (“JCDAO”) asserting claims for violations of various criminal statutes, the UCC, the Federal Trade Commission Act (“FTC Act”), several constitutional amendments, the Declaration of Independence, and the Magna Carta. Defendants move to dismiss Plaintiff’s claims for improper service and for failure to state a claim. STANDARDS I. Rule 12(b)(5) Federal Rule of Civil Procedure 12(b)(5) provides that insufficient service of process is grounds for dismissal of a claim. A Rule 12(b)(5) motion “is the proper vehicle for challenging the mode of delivery or lack of delivery of the summons and complaint.” Cadet v. Overlake Hosp. Med. Ctr., No. 2:24-CV-01452-LK, 2025 WL 2337225, at *1 (W.D. Wash. Aug. 13, 2025). “A federal court does not have jurisdiction over a defendant unless the defendant has been

served properly under [Federal Rule of Civil Procedure] 4.” Direct Mail Specialists, Inc. v. Eclat Computerized Techs., Inc., 840 F.2d 685, 688 (9th Cir. 1988); see also Omni Cap. Int'l, Ltd. v. Rudolf Wolff & Co., 484 U.S. 97, 104 (1987) (“Before a federal court may exercise personal jurisdiction over a defendant, the procedural requirement of service of summons must be satisfied.”). Although courts have also held that Rule 4 is flexible and should be liberally

1 Plaintiff’s Jackson County criminal matter was ongoing at the time of this Opinion and Order. construed if a party receives sufficient notice of the complaint and the defects in service are minor, United Food & Com. Workers Union v. Alpha Beta Co., 736 F.2d 1371, 1382 (9th Cir. 1984), absent substantial compliance with the requirements of Rule 4, “neither actual notice nor simply naming the defendant in the complaint will provide personal jurisdiction.” Benny v.

Pipes, 799 F.2d 489, 492 (9th Cir. 1986). “Service of process, under longstanding tradition in our system of justice, is fundamental to any procedural imposition on a named defendant.” Murphy Bros., Inc. v. Michetti Pipe Stringing, Inc., 526 U.S. 344, 350 (1999). See also Hensley v. Interstate Meat Distrib., Inc., No. 3:19-CV-0533-YY, 2020 WL 1677658, at *2 (D. Or. Jan. 10, 2020) (even for self-represented litigants, “[a] liberal construction of Rule 4 cannot be utilized as a substitute for the plain legal requirement as to the manner in which service of process may be had”) (quotation omitted)). “Once service is challenged, plaintiff[] bear[s] the burden of establishing that service was valid.” Brockmeyer v. May, 383 F.3d 798, 801 (9th Cir. 2004). II. Rule 12(b)(6) A motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) tests the sufficiency

of the claims. Navarro v. Block, 250 F.3d 729, 732 (9th Cir. 2001). “When reviewing a dismissal pursuant to Rule 12(b)(6), the Court accepts as true all facts alleged in the complaint and construes them “in the light most favorable to plaintiff.” Pino v. Cardone Cap., LLC, 55 F.4th 1253, 1257 (9th Cir. 2022) (quotation omitted). “Factual allegations must be enough to raise a right to relief above the speculative level on the assumption that all the allegations in the complaint are true (even if doubtful in fact)[.]” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations and footnote omitted). “‘Threadbare recitals of the elements of a cause of action” do not suffice to state a claim.” Pino, 55 F.4th at 1257 (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009)). To survive a motion to dismiss, a complaint “must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft, 556 U.S. at 678. A plaintiff must “plead[] factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. In other words, a complaint must

state a plausible claim for relief and contain “well-pleaded facts” that “permit the court to infer more than the mere possibility of misconduct[.]” Id. at 679. Courts must liberally construe pro se pleadings. Wilk v. Neven, 956 F.3d 1143, 1147 (9th Cir. 2020). Additionally, “[w]hen a plaintiff is pro se the district court is required to explain the deficiencies in a complaint, and only dismiss with prejudice if it is absolutely clear that the plaintiff could not cure the deficiencies by amendment.” Shavelson v. Hawaii C.R. Comm'n, 740 F. App'x 532, 534 (9th Cir. 2018) (quotation omitted). See also Rosati v. Igbinoso, 791 F.3d 1037, 1039 (9th Cir. 2015) (“A district court should not dismiss a pro se complaint without leave to amend unless it is absolutely clear that the deficiencies of the complaint could not be cured by amendment.”) (quotation omitted); Hundley v. Aranas, No. 21-15757, 2023 WL 166421, at *2

(9th Cir. Jan. 12, 2023) (same). DISCUSSION Defendants move to dismiss Plaintiff’s claims on the bases of improper service and failure to state a claim. I. Improper Service Defendants assert that Plaintiff did not properly effect service because Plaintiff himself served Defendants. ECF Nos. 2, 3. Defendants are correct. Federal Rule of Civil Procedure 4(c)(2) provides “[a]ny person who is . . . not a party may serve a summons and complaint” and courts have consistently held that “a party cannot themselves effectuate service[.]” Boose v. Musk, No. 25-CV-03366-AMO, 2025 WL 1836652, at *2 (N.D. Cal. July 3, 2025) (citing Smith v. Tempe Honda, 2010 WL 11627813, at *3 (D. Ariz. Mar.

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Bluebook (online)
Richard-Edward Lane v. Medford Oregon City Attorney’s Office and Jackson County District Attorney’s Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-edward-lane-v-medford-oregon-city-attorneys-office-and-jackson-ord-2025.