Uzoigwe v. Charter Commc'ns, LLC

CourtCourt of Appeals for the Second Circuit
DecidedMay 1, 2025
Docket24-1399
StatusUnpublished

This text of Uzoigwe v. Charter Commc'ns, LLC (Uzoigwe v. Charter Commc'ns, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Uzoigwe v. Charter Commc'ns, LLC, (2d Cir. 2025).

Opinion

24-1399-cv Uzoigwe v. Charter Commc’ns, LLC

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 1st day of May, two thousand twenty-five.

PRESENT: DENNIS JACOBS, DENNY CHIN, RAYMOND J. LOHIER, JR., Circuit Judges. ------------------------------------------------------------------ ONWY UZOIGWE,

Plaintiff-Appellant,

v. No. 24-1399-cv

CHARTER COMMUNICATIONS, LLC,

Defendant-Appellee. ------------------------------------------------------------------ FOR APPELLANT: ONWY UZOIGWE, pro se, Baltimore, MD

FOR APPELLEE: Michael D. Kabat, Shawna M. Miller, Kabat Chapman & Ozmer LLP, Atlanta, GA

Appeal from a judgment of the United States District Court for the Eastern

District of New York (Hector Gonzalez, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment of the District Court is AFFIRMED.

Plaintiff Onwy Uzoigwe, proceeding pro se, appeals from a judgment of

the United States District Court for the Eastern District of New York (Gonzalez,

J.) dismissing his breach of contract and negligence claims against Charter

Communications, LLC (“Charter”), his former employer. Uzoigwe filed this

lawsuit in New York State court on August 23, 2023, Charter removed the case to

federal court under diversity jurisdiction on September 27, 2023, and the District

Court denied Uzoigwe’s subsequent motions to remand the case to state court.

We assume the parties’ familiarity with the underlying facts and the record of

prior proceedings, to which we refer only as necessary to explain our decision to

affirm.

As a threshold matter, we decline Charter’s invitation to dismiss the

appeal because of Uzoigwe’s failure to comply with various procedural 2 requirements in his submissions on appeal. “[W]e liberally construe pleadings

and briefs submitted by pro se litigants,” McLeod v. Jewish Guild for the Blind, 864

F.3d 154, 156 (2d Cir. 2017) (quotation marks omitted), and we “generally do not

hold pro se litigants rigidly to the formal briefing standards set forth in” the

Federal Rules of Appellate Procedure, LoSacco v. City of Middletown, 71 F.3d 88, 93

(2d Cir. 1995).

I. Motions Seeking Remand

Uzoigwe challenges the District Court’s denial of his motion to remand

this case to state court and his subsequent motions for reconsideration of its

denial. Charter counters that we lack jurisdiction to consider these arguments

because Uzoigwe’s notice of appeal identified only the District Court’s order

granting Charter’s motion to dismiss and was filed before the entry of judgment.

Uzoigwe’s notice of appeal was premature because the District Court’s order

dismissing his claims granted him leave to amend. See Slayton v. Am. Exp. Co.,

460 F.3d 215, 223–24 (2d Cir. 2006). But because “the judgment was entered

before the appeal was heard” and “the appellee suffered no prejudice,” the entry

of final judgment shortly after Uzoigwe’s notice of appeal was filed cured that

defect. Sahu v. Union Carbide Corp., 475 F.3d 465, 468 (2d Cir. 2007). Uzoigwe’s

notice of appeal “designates . . . an order that adjudicates all remaining claims

3 and the rights and liabilities of all remaining parties.” Collymore v. Krystal Myers,

RN, 74 F.4th 22, 27 (2023) (quoting Fed. R. App. P. 3(c)(5)(A)). We therefore

construe the notice of appeal as “encompass[ing] the final judgment,” id.

(quotation marks omitted), permitting us to consider the merits of Uzoigwe’s

challenge to the District Court’s denial of remand, see Fed. R. App. P. 3(c)(4).

On the merits, we affirm. Uzoigwe argues that removal was improper

because of the forum defendant rule. “Under that rule, . . . a suit that

is ‘otherwise removable solely on the basis of . . . [diversity of citizenship] may

not be removed if any of the parties in interest properly joined and served as

defendants is a citizen of the State in which such action is brought.’” Gibbons v.

Bristol-Myers Squibb Co., 919 F.3d 699, 704-05 (2d Cir. 2019) (quoting 28 U.S.C.

§ 1441(b)(2)) (emphasis added). Thus, the forum defendant rule “is inapplicable

until a home-state defendant has been served in accordance with state law; until

then, a state court lawsuit is removable.” Id. at 705.

Uzoigwe properly attempted service on Charter by first class mail

pursuant to section 312-a of New York’s Civil Practice Law and Rules. But

section 312-a empowers defendants to defeat service through intransigency.

Section 312-a(b) provides that defendants must return a signed

acknowledgement of receipt, and that “[s]ervice is complete on the date the

4 signed acknowledgement of receipt is mailed or delivered to the sender.” N.Y.

C.P.L.R. § 312-a(b). New York courts have interpreted this requirement to mean

that a plaintiff has “failed to effectuate proper service of process” where the

defendant refuses to sign the acknowledgment required of it. See Wells Fargo

Bank, N.A. v. Wine, 935 N.Y.S.2d 664, 666 (3d Dep’t 2011); accord Cordero v.

Barreiro-Cordero, 10 N.Y.S.3d 454, 455 (2d Dep’t 2015) (mem.); Dominguez v.

Stimpson Mfg. Corp., 616 N.Y.S.2d 221, 222 (2d Dep’t 1994) (mem.); Shenko Elec.,

Inc. v. Hartnett, 558 N.Y.S.2d 859, 859 (4th Dep’t 1990) (mem.).

There is no dispute that Charter, a New York resident, filed its notice of

removal from New York State court before returning the required

acknowledgment of service to Uzoigwe. The only question is whether Charter’s

statutory non-compliance means that it was not properly served and therefore

that it can escape Uzoigwe’s choice of forum, the answer to which is — perhaps

unfairly — yes. Even though Uzoigwe did all that was required of him, and

even if he is correct that Charter’s “delay in returning the Acknowledgement”

was unjustified, Appellant’s Br. 26, Charter’s delay nevertheless suffices to defeat

the applicability of the forum defendant rule. Uzoigwe’s “lawsuit [was]

removable” because Charter had not yet been properly “served in accordance

5 with state law” at the time the case was removed. 1 See Gibbons, 919 F.3d at 705.

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