Tao v. Murphy

CourtDistrict Court, D. Nevada
DecidedJuly 11, 2025
Docket2:25-cv-00149
StatusUnknown

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

Bluebook
Tao v. Murphy, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Xin Tao, 2:25-cv-00149-JAD-MDC 4 Plaintiff(s), ORDER 5 vs. 6 Ryan Murphy, et al., 7 Defendant(s). 8 Pending before the Court is plaintiff’s Motion for Extension of Time and Alternative Service 9 (“Motion”) (ECF No. 25). For the reasons stated below the Court GRANTS the Motion in part and 10 DENIES the Motion in part. 11 DISCUSSION 12 I. BACKGROUND 13 This is a case arising from an alleged breach in rental agreement. Plaintiff alleges that Murphy 14 rented out the property at issue through Airbnb as a short-term rental, which was in violation of the 15 lease. 16 Plaintiff filed this action in the Eighth Judicial District Court, Clark County, Nevada on 17 December 1, 2024. Defendant Airbnb removed this action to federal court in the United States District 18 Court for the District of Nevada on January 23, 2025. On April 24, 2025, plaintiff filed a Motion for 19 Service by Publication or Alternative Means (ECF No. 21). On May 5, 2025, the Court denied the 20 Motion because plaintiff failed to show good cause and excusable neglect. See ECF No. 24. The Court 21 also denied the Motion because plaintiff failed to show that service by email or publication is reasonably 22 calculated to give defendant Ryan Murphy (“Murphy” or “defendant”) notice of the action. Id. The 23 Court allowed plaintiff to refile his Motion, addressing the deficiencies. Id. On May 12, 2025, plaintiff 24 refiled his Motion. ECF No. 25. Plaintiff now seeks service by email and certified mail. 25 // 1 II. LEGAL STANDARD 2 A. Time for Service 3 Pursuant to Rule 4(m) of the Federal Rules of Civil Procedure, defendant(s) must be served 4 within 90-days after the complaint is filed. Failure to do so is cause for dismissal without prejudice. Fed. 5 R. Civ. P. 4(m). However, “if the plaintiff shows good cause for the failure, the court must extend the 6 time for service for an appropriate period.” Id. Courts have broad discretion to extend time for service 7 under Rule 4(m). Efaw v. Williams, 473 D.3d 1038, 1041 (9th Cir. 2003). The Supreme Court has stated 8 that the 90-day time period for service contained in Rule 4(m) “operates not as an outer limit subject to 9 reduction, but as an irreducible allowance.” Henderson v. United States, 517 U.S. 654, 661, 116 S. Ct. 10 1638, 134 L. Ed. 2d 880 (1996). “On its face, Rule 4(m) does not tie the hands of the district court after 11 the… [90]—day period has expired. Rather, Rule 4(m) explicitly permits a district court to grant an 12 extension of time to serve the complaint after that… [90]—day period.” Mann v. American Airlines, 324 13 F.3d 1088, 1090 (9th Cir. 2003). The Advisory Committee Notes to Rule 4(m) state that the rule 14 “explicitly provides that the court shall allow additional time if there is good cause for the plaintiff's 15 failure to effect service in the prescribed… [90] days, and authorizes the court to relieve a plaintiff of the 16 consequences of an application of [Rule 4(m)] even if there is no good cause shown.” See Fed. R. Civ. 17 P. 4(m), Advisory Committee Notes, 1993 Amendments. 18 Rule 6(b)(1)(B) provides that a party that files an extension motion after deadline to act must 19 show that she failed to act prior to the deadline “because of excusable neglect.” Id.; see also Williams v. 20 Cnty. of Los Angeles, 2024 U.S. App. LEXIS 13767, at * 2 (9th Cir. 2024) (“Under Rule 4(m) a district 21 court…may discretionarily extend time for service upon a showing of excusable neglect.”) (citing 22 Lemoge v. United States, 587 F.3d 1188, 1198 (9th Cir. 2009)). 23 B. Method of Service 24 “[T]he Constitution does not require any particular means of service of process.” Rio Props. v. 25 Rio Int'l Interlink, 284 F.3d 1007, 1017 (9th Cir. 2002) (citing Mullane v. Central Hanover Bank & 1 Trust Co., 339 U.S. 306, 314, 70 S. Ct. 652, 94 L. Ed. 865 (1950)). Instead, it only requires that service 2 “be reasonably calculated to provide notice and an opportunity to respond.” Id. Service is governed by 3 Rule 4 of the Federal Rules of Civil Procedure. Rule 4(e)(1) provides that an individual within a judicial 4 district of the United States may be served by "following state law for serving a summons in an action 5 brought in courts of general jurisdiction in the state where the district court is located or where service is 6 made." Fed. R. Civ. P. 4(e)(1). 7 Rule 4.4 of the Nevada Rules of Civil Procedure governs methods of alternative service. It 8 provides that:

9 (1) If a party demonstrates that the service methods provided in Rules 4.2, 4.3, and 4.4(a) are impracticable, the court may, upon motion and without notice to the person being 10 served, direct that service be accomplished through any alternative service method. (2) A motion seeking an order for alternative service must: 11 (A) provide affidavits, declarations, or other evidence setting forth specific facts 12 demonstrating: (i) the due diligence that was undertaken to locate and serve the defendant; 13 and (ii) the defendant’s known, or last-known, contact information, including 14 the defendant’s address, phone numbers, email addresses, social media accounts, or any other information used to communicate with the 15 defendant; and (B) state the proposed alternative service method and why it comports with due 16 process. 17 Nev. R. Civ. P. 4.4(b)(1), (2). 18 The Ninth Circuit and the Nevada Rules of Civil Procedure permit service to be completed 19 through email and certified mail. See Rio Props., Inc. v. Rio Intern. Interlink, 284 F.3d 1007, 1014-15 20 (9th Cir. 2002) (holding that service by email is permitted when it is “reasonably calculated, under all 21 the circumstances, to apprise the interested parties of the action and afford them an opportunity to 22 present their objections.”); Nev. R. Civ. P. 4.4(d) (“In addition to any other service method, the court 23 may order a plaintiff to make reasonable efforts to provide additional notice of the commencement of 24 the action to a defendant using other methods of notice, including certified mail …email… or any other 25 method of communication.”). 1 III. ANALYSIS 2 A. EXTENSION OF TIME 3 a. Good Cause 4 Generally, “good cause” is equated with diligence. See Wright & Miller, Federal Practice and 5 Procedure: Civil 3d § 1337. A showing of good cause requires more than inadvertence or mistake of 6 counsel. Townsel v. Contra costa Cnty., Cal., 820 F.2d 319, 320 (9th Cir. 1987). Here, the Court finds 7 that plaintiff has been diligent in attempting to serve Murphy. Plaintiff has been attempting to serve 8 Murphy at several of his last known locations since the inception of this case and has only failed due to 9 an inability to locate him. ECF No. 25-1- 25-4. Therefore, the Court finds that good cause has been 10 established. 11 b.

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