Rowan v. PepsiCo Inc

CourtDistrict Court, E.D. Arkansas
DecidedAugust 31, 2022
Docket4:21-cv-00911
StatusUnknown

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

Bluebook
Rowan v. PepsiCo Inc, (E.D. Ark. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

TIFFANY ROWAN PLAINTIFF

v. Case No. 4:21-cv-00911 KGB

PEPSICO, INC., NEW BERN TRANSPORTATION CORPORATION, and BRYSON JURIEL BOWERS DEFENDANTS

ORDER

Before the Court are several pending motions, including separate defendants PepsiCo, Inc. (“PepsiCo”) and New Bern Transportation Corporation’s (“New Bern”) amended notice of removal, defendants PepsiCo, New Bern, and Bryson Juriel Bowers’ motion to dismiss, and plaintiff Tiffany Rowan’s motion for leave to amend complaint (Dkt. Nos. 3, 4, 7). On October 7, 2021, PepsiCo and New Bern removed this case to this Court from the Circuit Court of Pulaski County, Arkansas (Dkt. No. 1). The Court addresses each pending motion in turn. I. PepsiCo And New Bern’s Amended Notice Of Removal On October 15, 2021, separate defendants PepsiCo and New Bern filed an amended notice of removal (Dkt. No. 3). PepsiCo and New Bern assert that their amended notice of removal is timely because it is filed within 30 days of PepsiCo and New Bern discovering and obtaining a copy of Ms. Rowan’s complaint filed in state court and because no defendant had been served with process of the state court complaint (Id., ¶ 24). PepsiCo and New Bern further assert that they reserved the right to amend or revise their original notice of removal filed within 30 days of the filing of the state court action (Id.). No party responded in opposition to the motion. 28 U.S.C. §§ 1441 and 1446 govern removal of a state court action to federal court. Pursuant to § 1446(b), “[t]he notice of removal of a civil action or proceeding shall be filed within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based. . . .” A notice of removal may be amended during the 30 day period during which the removal may be filed. Whitehead v. The Nautilus Group, Inc., 428 F.Supp.2d 923, 928–29 (W.D. Ark.

2006); Lindsey v. Dillard's, Inc., 306 F.3d 596, 600 (8th Cir. 2002). Although a notice may be amended after the 30 day period, the notice can only be amended to add specific facts supporting the originally stated grounds for removal or to clarify the grounds for removal as stated in the original notice. Id. The amendment cannot add new grounds for removal once the 30 day period has expired. Id. For good cause shown, the amended notice of removal is granted (Dkt. No. 3). II. Defendants’ Motion To Dismiss On October 15, 2021, defendants PepsiCo, New Bern, and Mr. Bowers filed a motion to dismiss (Dkt. No. 4). Defendants assert that Ms. Rowan’s complaint improperly named as a defendant “New Bern Transportation Corporation,” which is not an entity capable of being sued

(Id., ¶ 4). Defendants assert that, since filing her complaint on September 8, 2021, Ms. Rowan has “undertaken no effort to obtain issuance of any summons in this action” and has “not attempted in any respect to serve any defendant with process.” (Id., ¶¶ 7–10). Accordingly, defendants move to dismiss Ms. Rowan’s complaint for insufficient process and insufficient service of process pursuant to Rules 12(b)(4) and 12(b)(5) of the Federal Rules of Civil Procedure (Id.). In the alternative, defendants request that this Court enter an order requiring Ms. Rowan to serve process on all defendants pursuant to 28 U.S.C. § 1448 and in accordance with Rule 4 of the Federal Rules of Civil Procedure (Id.). Ms. Rowan filed a response in opposition to defendants’ motion to dismiss (Dkt. No. 6). In her response, Ms. Rowan agrees that she must properly serve defendants and represents that she “is in the process of doing so.” (Id., ¶ 8). Ms. Rowan asserts that defendants’ motion is untimely because the time for service has not expired (Id., ¶ 6–7). She cites Rule 4(m) of the Federal Rules

of Civil Procedure for the proposition that plaintiffs have 90 days after a complaint is filed to complete service (Id., ¶ 4). Ms. Rowan maintains that because she filed her complaint on September 8, 2021, she has until December 8, 2021, to serve defendants (Id., ¶ 5). Federal Rules of Civil Procedure 4(m) provides in relevant part that, “[i]f a defendant is not served within 90 days after the complaint is filed, the court—on motion or on its own after notice to the plaintiff—must dismiss the action without prejudice against the defendant or order that service be made within a specified time.” Fed. R. Civ. P. 4(m). Here, Ms. Rowan filed her complaint September 8, 2021 (Dkt. No. 2). Separate defendants PepsiCo and New Bern filed their notice of removal on October 7, 2021, and their amended notice of removal on October 15, 2021 (Dkt. Nos. 1, 3). Also on October 15, 2021—just 37 days after Ms. Rowan filed her complaint—

PepsiCo, New Bern, and Mr. Bowers filed the instant motion to dismiss (Dkt. No. 4). The Court finds that defendants’ motion to dismiss was premature. On review of the docket, the Court also observes that Ms. Rowan filed an affidavit in completion of service of process as to each of the defendants on December 7, 2021 (Dkt. No. 9). For these reasons, the Court denies defendants’ motion to dismiss (Dkt. No. 4). III. Ms. Rowan’s Motion For Leave To Amend Complaint On October 29, 2021, Ms. Rowan filed a motion for leave to amend complaint (Dkt. No. 7). Defendants filed a response (Dkt. No. 8). For the following reasons, the Court grants Ms. Rowan’s motion (Dkt. No. 7). Ms. Rowan seeks to amend her complaint to identify correctly and to serve separate defendant New Bern pursuant to Rules 4(a) and Rule 15(c) of the Federal Rules of Civil Procedure (Dkt. No. 7). She states that her initial complaint incorrectly named “New Bern Transport Corporation” as “New Bern Transportation Corporation” alongside defendants PepsiCo and Mr.

Bowers (Id.). Ms. Rowan asserts that this is “a true misnomer situation” because she named the right defendant but by the wrong name (Id., ¶ 3). Ms. Rowan contends that, because the statute of limitation passed on September 14, 2021, she will sustain substantial prejudice if the Court does not grant her motion and allow her to correct the misnomer (Id.). Separate defendants PepsiCo and New Bern concede that “the misnomer needs to be corrected and a properly amended complaint would be the proper course of action,” but object to amendment of Ms. Rowan’s complaint on the basis that there is “another issue that also needs to be addressed and corrected.” (Dkt. No. 8, at 1). According to PepsiCo and New Bern, PepsiCo “should never have been named as a defendant in this litigation” because the entity has no factual connection to this case other than its status as an upstream parent of New Bern Transport

Corporation (Id., at 2). PepsiCo and New Bern therefore take the position that, because Ms.

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Rowan v. PepsiCo Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rowan-v-pepsico-inc-ared-2022.