Trimble v. United States

CourtDistrict Court, N.D. Texas
DecidedJuly 31, 2025
Docket3:24-cv-01615
StatusUnknown

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

Bluebook
Trimble v. United States, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

AISHA TRIMBLE, § PLAINTIFF, § § V. § CASE NO. 3:24-CV-1615-L-BK § UNITES STATES OF AMERICA, § RESPONDENT. §

FINDINGS, CONCLUSIONS AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Pursuant to 28 U.S.C. § 636(b) and Special Order 3, Doc. 7, this pro se case was referred to the United States magistrate judge for pretrial management. Before the Court for findings and a recommended disposition is Defendant’s Motion to Dismiss. Doc. 21. Defendant asserts that dismissal is warranted under Federal Rule of Civil Procedure 12(b)(5) or, alternatively, Rules 12(b)(1) and 12(b)(6). See id. For the reasons stated below, the motion should be GRANTED. I. BACKGROUND A. Nature of Suit and Claims Plaintiff Aisha Trimble, a United States military veteran, brings this civil action against the United States, alleging, inter alia, that her civil rights were violated when she not selected for three possible federal job vacancies because her potential employers failed to account for her veterans’ preference eligibility under the Veterans Preference Act of 1944 (“VPA”). See Doc. 1, passim (Complaint). Plaintiff alleges that in 2021 and 2022, she applied for three federal executive assistant positions: (1) a U.S. Department of Veterans Affairs (VA) vacancy, (2) a Federal Emergency Management Agency (FEMA) vacancy, and (3) a U.S. Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) vacancy.1 Doc. 1, ¶¶ 20, 32, 47. Plaintiff was not selected for either of the three positions, and repeatedly challenged her non-selections with multiple federal agencies, including the U.S. Department of Labor (DOL) and the Merit Systems Protection Board (MSPB). Doc. 1, ¶¶ 2, 21, 33, 47. At each stage of the investigative and appeal processes, she was informed that because she had applied for merit promotion jobs, she was eligible to apply

but was not entitled to any veterans’ preference under the Veterans Employment Opportunities Act of 1988 (VEOA). Doc. 1 at 24, 42-55, 58-69, 71, 96-104, 113, 123-31. Plaintiff appealed the MSPB’s decisions to the United States Court of Appeals for the Federal Circuit. Doc. 1, ¶¶ 29, 43, 56. In each case, the Federal Circuit upheld the MSPB’s decision, finding that Plaintiff had failed to demonstrate any violation. Doc. 1 at 58-69, 106-11, and 133-41. Plaintiff subsequently filed this lawsuit alleging that her civil rights were violated by the DOL’s, MSPB’s, and the Federal Circuit’s determinations that her veterans’ preference rights were not violated when she was not selected for any of the three federal job vacancies.2 See generally Doc. 1. Plaintiff asserts six causes of action, including three civil-rights claims

alleging violations of 18 U.S.C. §§ 241, 242 and 42 U.S.C. §§ 1983, 1985, and 1986 (id. ¶¶ 65- T67); two claims alleging Fifth Amendment violations (id. ¶¶ 68-69); and a claim alleging various violations of veterans’ preference rights under 5 U.S.C. § 2302 (id. ¶ 70). Plaintiff also

1 Unless otherwise noted, the factual recitation pertaining to Plaintiff’s non-selection is taken from the Complaint, which the Court must accept as true for purposes of resolving Defendant’s Motion to Dismiss.

2 The Court liberally construes Plaintiff’s filings with all possible deference due a pro se litigant. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (noting pro se pleadings are “to be liberally construed” and “held to less stringent standards than formal pleadings drafted by lawyers”); Cf. FED. R. CIV. P. 8(e) (“Pleadings must be construed so as to do justice.”). asserts claims under the Federal Tort Claims Act (FTCA) (id. ¶¶ 15, 72), but her complaint does not assert any actual cause of action under the FTCA. As relief, Plaintiff requests $2 million in compensatory damages. Doc. 1, ¶ 71. B. Service of Process After filing, Plaintiff requested the Clerk enter a default against the United States and

included an affidavit asserting that she effected service on the United States Attorney for the Northern District of Texas (USAO). See Doc. 10 (request for entry of default); Doc. 10-1 (affidavit supporting request for entry of default); see also Doc. 9 (proof-of-service filings). Plaintiff then moved for a default judgment, Doc. 11, and filed a motion to vacate the referral of this matter to the undersigned magistrate judge, Doc. 12. Both motions were denied initially and upon reconsideration by the presiding district judge. Doc. 13; Doc. 14; Doc. 21. Specifically, the district judge left the matter of Plaintiff’s request for entry of default to the clerk of court and undersigned magistrate judge, noting that the Court “questions whether service of process was effected in accordance with Federal Rule of Civil Procedure 4(i),” and referencing a similar

service issue raised in Plaintiff’s related case in filed in this district (Civil Action No. 3:24-CV- 1933-G-BT). Doc. 21. In the interim, the USAO filed a Notice Regarding Deficient Service of Process (“Notice”), asserting that the United States had not been properly served with process. See Doc. 19. The Notice avers that while the proof-of-service materials that Plaintiff had filed purported to show service on the USAO by mail, the USAO had no record of receiving the mailing in question and, indeed, the recipient signature of “O. Tonche” was not that of anyone employed at the USAO. Doc. 19 at 3. The Notice also recites that the Federal Rules of Civil Procedure specifically require any mailed service of process to the United States Attorney to be addressed to the “civil process clerk” of the U.S. Attorney’s Office for precisely the reason of ensuring that such mail is delivered correctly. Doc. 19 at 3. Notably, the USAO has repeatedly offered to accept service from Plaintiff, but Plaintiff has not responded to any of its offers. See Doc. 21 at 12; Doc. 20. Despite that fact and the pointed observation of the district judge calling into question the sufficiency of service here,

Plaintiff apparently continues to disclaim assertions that the United States was not properly served or that additional service of process is necessary. See Doc. 16 at 1, 3; see also Doc. 15 at 6. II. APPLICABLE LAW A. Rule 12(b)(5) Rule 12(b)(5) permits a challenge to the plaintiff’s method of service or the lack of delivery of the summons and complaint. See FED. R. CIV. P. 12(b)(5); Coleman v. Bank of N.Y.

Mellon, 969 F. Supp. 2d 736, 745 (N.D. Tex. 2013) (citations omitted). “When service of process is challenged, the serving party bears the burden of proving its validity or good cause for failure to effect timely service.” Sys. Signs Supplies v. U.S. Dep’t of Just., 903 F.2d 1011, 1013 (5th Cir. 1990) (per curiam) (citations omitted). “Good cause” under Rule 4(m) is defined as “at least as much as would be required to show excusable neglect . . . simple inadvertence or mistake of counsel or ignorance of the rules usually does not suffice.” Lambert v. United States, 44 F.3d 296, 299 (5th Cir. 1995) (quoting Winters v.

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Bluebook (online)
Trimble v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trimble-v-united-states-txnd-2025.