Santiago v. Chill

CourtDistrict Court, W.D. Kentucky
DecidedMay 30, 2025
Docket3:21-cv-00720
StatusUnknown

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

Bluebook
Santiago v. Chill, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION ALBERTO JAMES SANTIAGO SR. Plaintiff v. Civil Action No. 3:21-cv-00720-RGJ ELISHIA CHILL, ET AL. Defendant * * * * * MEMORANDUM OPINION & ORDER Defendants Elisha Chill (“Chill”) and Key Property Management (“Key Property”) move to dismiss the complaint. [DE 81]. Plaintiff Alberto James Santiago Sr. (“Santiago”) missed the initial filing deadline to respond. After several orders and a show cause hearing on March 19, 2025, Santiago responded. [DE 94]. Chill and Key Property did not file a reply. For the reasons below, Chill’s and Key Property’s Motion to Dismiss [DE 81] is GRANTED, and Santiago’s remaining claims are DISMISSED WITH PREJUDICE for failure to prosecute. I. BACKGROUND Santiago is a pro se plaintiff claiming damages of one billion dollars in a suit alleging discrimination based on his national origin and disability under The Fair Housing Act, Title VI of the Civil Rights Act of 1964, and Section 504 of the Rehabilitation Act. [DE 1; DE 10 at 209].

Santiago brings these claims against Key Property, the property management company for California Square One Apartments where Santiago lived, and Chill, their property manager. [DE 1 at 3]. While it is somewhat unclear from the complaint, it appears that Santiago alleges national origin and disability discrimination against Chill and Key Property for failing to fix his door and threatening to evict him. [DE 1-1 at 20]. Santiago alleges that Chill made derogatory comments about Puerto Ricans while threatening to evict him and refused to repair a broken latch on his door. [Id]. This case has been pending over three years. On December 2, 2021, Santiago filed a complaint with the Court against Chill and Key Property, as well as Laurie Hext (“Hext”), Emily Fosse (“Fosse”), and CS1 KY, LLC. [DE 1]. On March 3, 2023, this Court dismissed Santiago’s claims against Fosse and CS1 KY, LLC., as well as all claims under 42 U.S.C. § 1983 and Title VIII of the Civil Rights Act of 1968. [DE 10]. Later, the Court dismissed the claims against Hext

for insufficient service and failure to prosecute. [DE 54]. While there have been numerous motions and objections filed over the course of this case, they are largely omitted from this background because they have no direct bearing on the motions before the Court. Santiago has not responded to any requests for admission or participated in discovery. [DE 82]. The November 11, 2024, discovery deadline has passed. [DE 70]. II. MOTION TO DISMISS FOR IMPROPER SERVICE [DE 81] The Court has authority to dismiss a defendant and claims against a defendant for a plaintiff’s failure to prosecute, failure to comply with the Federal Rules of Civil Procedure, or failure to comply with a court order. Fed. R. Civ. P. 41(b); Schafer v. City of Defiance Police

Dept., 529 F.3d 731, 736 (6th Cir. 2008). Fed. R. Civ. P. 4(c)(2) requires that service may be made by “[a]ny person who is at least 18 years old and not a party.” Fed. R. Civ. P. 4(c)(2) (emphasis added). A party to a lawsuit is required to use a process server to effect service, and any attempt by one party to personally serve another party in the litigation renders the service improper. Id.; Lee v. George, No. 3:11-CV-607-CRS, 2012 WL 1833389, at *3 (W.D. Ky. May 18, 2012) (“Since Lee is a party to the action, his attempt to serve process upon Judge George renders the service improper.”). This remains true even if service is attempted by certified mail. Constien v. United States, 628 F. 3d 1207, 1213-15 (10th Cir. 2010) (“Even when service is effected by use of the mail, only a nonparty can place the summons and complaint in the mail.”). The less stringent standards applied to pro se litigants do not apply to rules for proper service and district courts in this circuit have routinely dismissed cases improperly served directly by pro se litigants in the past under Fed. R. Civ. P. 4(m). Greene v. United States, No. 6:19-CV-00024-GFVT, 2021 WL 1214499, at *18 (E.D. Ky. Mar. 30, 2021), aff’d, No. 21-5398, 2022 WL 13638916 (6th Cir. Sept. 13, 2022).

Rule 12(b) requires that a motion asserting the defense of insufficient service of process under Rule 12(b)(5) “must be made before pleading if a responsive pleading is allowed.” Fed. R. Civ. P. 12(b). A party waives the defense of insufficient service of process if he fails to include the defense either in a motion under Rule 12 or in a responsive pleading. See Fed. R. Civ. P. 12(h)(1)(B). Rule 12(h)(1)(B) requires a defendant “to either (i) ‘make’ an insufficient-service defense in a pre-answer motion or (ii) simply ‘include’ the defense in the answer.” King v. Taylor, 694 F.3d 650, 657 (6th Cir. 2012). A defendant has “the option to preserve the defense in either manner,” provided he has not already filed a motion under Fed. R. Civ. P. 12 in which he failed to assert the defense. Id. Both Chill and Key Property have repeatedly asserted the defense of

insufficient service of process throughout this litigation, including preserving the argument in their answer. [DE 42 at 398]. In the proof of service Santiago declared under penalty of perjury that he “[p]ersonally [s]erved the summons on the Respondent Elisha Chill” and “[p]ersonally [s]erved the summons on the Respondent Key Property Management.” [DE 1-33 at 171]. Santiago personally signed the proof of service as the process server and checked the box verifying that he personally served the summons. [Id. at 183, 187, 188]. Santiago further attested that he served the summons by regular and certified mail to both defendants. [Id. at 180]. As a party to this litigation, Santiago cannot serve process himself and was required to use a process server or the Court to effect service. Lee, 2012 WL 1833389 at 3. Although the forms provided by Santiago are conflicting about whether they were served by certified mail, or directly to the defendants at the listed address, there is no doubt that Santiago effected service personally as a party to this litigation. As such, this service was improper, and as the set ninety-day deadline for service has long since passed, the Court must dismiss absent a finding of good cause. Fed. R. Civ. P. 4(m).

Rule 4(m) of the Federal Rules of Civil Procedure provides that a court “must extend the time for service for an appropriate period” when plaintiff can show good cause for its inability to serve a defendant within 90 days. Fed. R. Civ. P. 4(m).

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