Zurich American Insurance Company v. Chavers

CourtDistrict Court, D. Nevada
DecidedJuly 1, 2025
Docket2:25-cv-00240
StatusUnknown

This text of Zurich American Insurance Company v. Chavers (Zurich American Insurance Company v. Chavers) 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
Zurich American Insurance Company v. Chavers, (D. Nev. 2025).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 * * * 5 Case No. 2:25-cv-00240-CDS-BNW 6 Zurich American Insurance Company,

7 Plaintiff, ORDER

8 v.

9 Austin Chavers, et al.,

10 Defendants.

11 12 Before this Court is Plaintiff’s Motion to Serve Certain Defendants by Publication. ECF 13 No. 28. No opposition was filed. Because Plaintiff failed to meet the requirements for service by 14 publication, this Court denies the motion without prejudice. However, this Court, in its discretion, 15 extends the time for service. 16 I. BACKGROUND 17 This is an interpleader action that Plaintiff, an insurance company, commenced to 18 distribute underinsured motorist benefits to persons involved in a vehicle accident. ECF No. 28 at 19 2. Defendants were passengers in a vehicle, insured by Plaintiff, that may have a claim to the 20 insurance proceeds. In the complaint, Plaintiff names 15 defendants, 12 of which have appeared 21 in the case. The remaining three defendants—Curtis Edge, Nathan Schmidt, and Debora Schantz 22 —have not been served. See ECF No. 27 (notice of intent to dismiss for lack of service). The 23 deadline to file proof of service was May 5, 2025. See ECF No. 1. Plaintiff filed the present 24 motion on June 3, 2025. ECF No. 28. 25 In that motion, Plaintiff states that it ran a Westlaw people search report that yielded an 26 address for each unserved Defendant, and it attempted service once at those addresses. Id. at 2–3. 27 When service was unsuccessful, Plaintiff explains it requested skip traces that, again, yielded an 1 Defendant Edge, Plaintiff states the process server spoke with the residents at each address, and 2 they advised they did not know him. Id. at 2. As to Defendant Schmidt, the process server noted 3 that the residences were empty and confirmed as much with the property manager. Id. at 3. 4 Finally, as to Defendant Schantz, the process server spoke with the residents at each address, and 5 they advised that Defendant Schantz was either unknown or had moved. Id. The process server 6 further called Defendant Schantz, but did not speak to her. Id. 7 II. ANALYSIS A. This Court denies Plaintiff’s motion to serve by publication because Plaintiff has 8 not met the requirements under Nevada Rule of Civil Procedure 4.4(c). 9 The Constitution does not require any particular means of service of process. Rio Props., 10 Inc. v. Rio Intern. Interlink, 284 F.3d 1007, 1017 (9th Cir. 2002) (citing Mullane v. Central Hanover 11 Bank & Trust Co., 339 U.S. 306, 314 (1950)). Instead, it requires only that service “be reasonably 12 calculated to provide notice and an opportunity to respond.” Id. To that end, service of process is 13 governed by Rule 4 of the Federal Rules of Civil Procedure. 14 Rule 4(e) governs service of individuals located within a judicial district of the United 15 States. Fed. R. Civ. P. 4(e). It provides that service is proper by serving an individual in 16 accordance with law of the state where the district court is located. Id. This Court is located in the 17 District of Nevada. The Nevada Rules of Civil Procedure (“NRCP”), in turn, allow for service by 18 publication. NRCP 4.4(c). 19 A litigant who desires to effect service by publication must meet eight requirements. 20 NRCP 4.4(c). The litigant must (1) establish that “the service methods provided in [NRCP] 4.2, 21 4.3, and 4.4(a) and (b) are impracticable”;1 (2) demonstrate that the defendant cannot, after due 22 diligence, be found, or that the defendant seeks to avoid service of process through concealment; 23 24 1 NRCP 4.2 tracks federal Rule 4(e)(2) and permits service of an individual by either delivering a 25 copy of the summons and complaint to the individual personally, leaving the copies at the individual’s dwelling with a person of suitable age and discretion, or delivering the copies to an 26 agent authorized by appointment or by law to receive service of process. NRCP 4.2(a); Fed. R. 27 Civ. P. 4(e)(2). NRCP 4.3 governs service of individuals located outside Nevada or outside the United States. NRCP 4.4(a) governs service in a manner prescribed by statute. And NRCP 4.4(b) 1 (3) establish through pleadings or other evidence that a cause of action exists against the 2 defendant; (4) demonstrate that the defendant is a necessary or proper party to the action; (5) set 3 forth specific facts demonstrating the efforts plaintiff made to locate and serve the defendant; 4 (6) provide the proposed language of the summons to be used in the publication, briefly 5 summarizing the claims asserted and the relief sought; (7) suggest one or more newspapers in 6 which the summons should be published that are reasonably calculated to give the defendant 7 actual notice; and (8) provide the defendant’s last-known address, the dates during which 8 defendant lived at that address, and confirmation that plaintiff is unaware of any other address at 9 which defendant has resided since that time or at which defendant can be found. NRCP 4.4(c). 10 Here, Plaintiff has not made the requisite showing under NRCP 4.4(c)—and, by 11 extension, federal Rule 4(e)(1)—to effect service of process by publication. Plaintiff hardly 12 addressed any of the NRCP 4.4(c) requirements. Although Plaintiff has met some requirements, it 13 has not met others. 14 i. Plaintiff has met requirements three, four, six, seven, and eight. 15 Plaintiff has shown that a cause of action exists against the unserved Defendants 16 (requirement three). A cause of action is “[a] group of operative facts giving rise to one or more 17 bases for suing” or a “legal theory of a lawsuit.” Cause of Action, Black’s Law Dictionary (12th 18 ed. 2024). Plaintiff’s theory, set forth in its pleadings, meets this requirement. See ECF No. 1. 19 Relatedly, Plaintiff has shown that the unserved Defendants are necessary and proper parties to 20 this matter (requirement four) because they may have been injured in the accident and be entitled 21 to the insurance proceeds. ECF No. 28 at 2; ECF No. 1 at 2–3. 22 In addition, Plaintiff provided the proposed language of the summons to be used in 23 publication (requirement six)2 and suggested two newspapers, the Los Angeles Times and Las 24 2 NRCP 4.4 provides that litigants who desire to serve their adversaries by publication must 25 “provide the proposed language of the summons to be used in the publication, briefly 26 summarizing the claims asserted and the relief sought[.]” NRCP 4.4(c)(2)(C). Thus, NRCP 4.4 speaks to the content of the summons. However, the required content of summonses issued by the 27 federal court is governed by Federal Rule of Civil Procedure 4. See Fed. R. Civ. P. 4(a). Rule 4 is consonant with the Rules Enabling Act and the U.S. Constitution because it does not “abridge, 1 Vegas Review Journal, to publish the summonses in (requirement seven). ECF No. 28 at 5–6. 2 These newspapers are reasonably calculated to give the unserved Defendants’ actual notice 3 because, based on previous addresses, they reside in either Las Vegas or Los Angeles. ECF No. 4 28 at 2–3, 5.

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