Tippins v. Common Ground

CourtDistrict Court, E.D. Michigan
DecidedMay 15, 2025
Docket4:24-cv-10923
StatusUnknown

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

Bluebook
Tippins v. Common Ground, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

MYESHA TIPPINS, Case No. 24-10923

Plaintiff, F. Kay Behm v. United States District Judge

COMMON GROUND,

Defendant. ___________________________ /

OPINION AND ORDER ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT (ECF No. 17)

I. PROCEDURAL HISTORY Defendant, Common Ground, brings a motion for summary judgment seeking dismissal of the complaint based on defective service of process. (ECF No. 17). Plaintiff, Myesha Tippins, opposes the motion. (ECF No. 19). Common Ground also filed a reply in support of its motion. (ECF No. 24). The court held a hearing on May 14, 2025, and took the matter under advisement. For the reasons set forth below, the court finds that Defendant was not properly served with the summons and complaint. II. FACTUAL BACKGROUND Plaintiff filed this action on April 10, 2024. The summons thus had an expiration date of July 9, 2024. According to Common Ground, on May 3, 2024,

Tippins mailed the Complaint to Common Ground’s former address. Common Ground says that based on the wrong address, the mailing bounced back and forth between USPS offices in Detroit and Pontiac for more than three months. In

any event, Common Ground maintains that the complaint was not served before the summons expired. On August 22, 2024, Tippins filed a proof of service which claimed that the

summons and complaint were mailed on July 5, 2024, to Defendant at 1410 S. Telegraph Rd, Bloomfield Hills, MI 48302 and to the Department of Licensing and Regulatory Affairs (LARA). (ECF No. 5, Certificate of Service). According to

Common Ground, this mailing was never received. According to Plaintiff, she attempted to serve Defendant in person at the address listed on LARA, but the

location was vacant. (ECF No. 19-1). On July 5, 2024, Counsel says she mailed the summons and complaint to LARA and sent the summons and complaint via registered mail to the registered agent’s address, at 30200 Telegraph Rd, Suite

300, Bingham Farms MI 48025, but has not submitted a proof of service showing this attempted service. (ECF No. 19-1). Plaintiff then filed a request for entry of a default against Common Ground

on September 4, 2024. (ECF No. 6, Request for Default). On September 5, 2024, the Clerk of the Court denied the default request because there was no proof that

Common Ground had been served; more specifically it noted a lack of a green card. (ECF No. 7, Notice of Denial). On September 10, 2025, Common Ground filed an answer to the complaint with affirmative defenses, including the defense

that Tippins “has not properly served Defendant with the Summons and Complaint, or otherwise, the Service of Process was not effectuated as required under the court rules.” (ECF No. 8, PageID.43, ¶ 2). Common Ground also listed

as an affirmative defense that “Defendant was not served with Plaintiff’s Complaint prior to the expiration of the Summons issues in this matter by the Court.” Id. at ¶ 3. Common Ground also raised these defenses in the parties’

Rule 26(f) Joint Discovery Plan. (ECF No. 14, § 1). III. ANALYSIS

As explained in Boulger v. Woods, 306 F. Supp. 3d 985, 992 (S.D. Ohio 2018), aff’d, 917 F.3d 471 (6th Cir. 2019), the Sixth Circuit has noted that summary judgment is an “improper” vehicle to challenge service of process

“because the defense ‘involves a matter in abatement and does not go to the merits of the action.’” King v. Taylor, 694 F.3d 650, 657 n.2 (6th Cir. 2012) (quoting United States v. Marple Cmty. Record, Inc., 335 F. Supp. 95, 101 (E.D. Pa.

1971)). “Nevertheless, when the defense has been preserved in an answer and is later raised in a pre-trial motion, a court will look past the label chosen by the

movant and treat the motion as a request for a ruling on the defense made under ... Rule 12(i).” Id. Because the basis for Common Ground’s summary judgment motion is not that it is entitled to judgment on the merits, but that Plaintiff's

failure to perfect service deprives this court of personal jurisdiction over Defendant, the court will construe the motion as seeking dismissal under Rule 12(b)(5). See Boulger, supra.

“Due process requires proper service of process for a court to have jurisdiction to adjudicate the rights of the parties.” O.J. Distrib., Inc. v. Hornell Brewing Co., Inc., 340 F.3d 345, 353 (6th Cir. 2003). Plaintiff bears the burden of

perfecting service of process and showing that proper service was made. Sawyer v. Lexington-Fayette Urb. Cnty. Gov't, 18 F. App’x 285, 287 (6th Cir. 2001) (citing

Byrd v. Stone, 94 F.3d 217, 219 (6th Cir. 1996)). Service on a corporation is controlled by Rule 4(h), which allows service of process on a corporation (1) by delivering a copy of the summons and complaint

to an officer, managing or general agent, or other agent authorized by appointment or law to receive process, and if the agent is authorized by statute and the statute so requires, by mailing a copy to the defendant; or (2) in the

manner set forth in Rule 4(e)(1), “which in turn authorizes service upon a corporation in accordance with Michigan state law.” The governing state law,

Michigan Court Rule 2.105(D)(1), does not permit service by mail on the registered agent, as made clear by reading subsection (D)(1) in conjunction with subsection (D)(2), which includes a registered mail provision. Michigan law allows

service on a corporation “by serving a summons and a copy of the complaint on an officer or the resident agent personally or, alternatively, by serving a summons and a copy of the complaint on a director, trustee or person in charge of the

office as well as sending a summons and a copy of the complaint by registered mail.” Vasher v. Kabacinski, 2007 WL 295006, *2 (E.D. Mich. 2007) (emphasis added). And the “deliberate distinction” between subsection (D)(1) and

subsection (D)(2) “suggests that the Michigan Supreme Court did not intend that the term ‘serving’ be interpreted as synonymous with ‘mailing.’” State Farm Fire

and Cas. Co. v. Hamilton Beach/Proctor–Silex, Inc., 2007 WL 127909, *4 (E.D. Mich. 2007). In this case, Plaintiff only served the summons and complaint by mail, and thus did not comply with either of the proper service options available

for service of corporations under Rule 4(h) and Michigan law. Therefore, plaintiff’s service of the summons and complaint by registered mail only was not proper under Michigan law. Further, contrary to Plaintiff’s suggestion,

Defendant’s actual notice of the complaint does not serve to cure defective service of process. Friedman v. Estate of Presser, 929 F.2d 1151, 1156 (6th Cir.

1991). Plaintiff makes several arguments to avoid the conclusion that proper service was not made. First, she claims that Defendant failed to maintain a

registered agent and thus, service was proper under Mich. Ct. Rule 2.105(D)(4). This provision allows services by registered mail to the corporation and the Michigan Bureau of Commercial Services if the corporation has failed to appoint

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Tippins v. Common Ground, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tippins-v-common-ground-mied-2025.