Alford et al v. Chevron U.S.A. Inc. et al
ORDER AND REASONS granting 33 Motion to Remand and DENYING Chevron's motion to amend the Notice of Removal.. Signed by Chief Judge Sarah S. Vance on 1/6/14. (Attachments: # 1 remand letter) (Reference: ALL CASES)(jjs, )
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
CATHERINE P. ALFORD, ET AL.
CHEVRON U.S.A. INC., ET AL.
ORDER AND REASONS
Plaintiffs move to remand this matter to state court,1 and
defendant Chevron U.S.A., Inc. moves to amend its Notice of
Removal.2 For the following reasons, the Court GRANTS plaintiffs'
motion, DENIES Chevron's motion, and remands this case to state
Plaintiffs filed this lawsuit on May 2, 2013, in the 25th
Judicial District Court for the Parish of Plaquemines.3
Plaintiffs then filed two supplemental amending petitions, one on
May 3, 2013,4 and one on July 30, 2013.5 Plaintiffs served all of
the defendants during the period between August 6, 2013, and
R. Doc. 33.
R. Doc. 82.
R. Doc. 1-2 at 5.
R. Doc. 1-2 at 2.
R. Doc. 1-3 at 129.
August 12, 2013.6 On August 16, 2013, Chevron timely removed the
action to this Court.7 Chevron's Notice of Removal states that
the Court has diversity jurisdiction over this lawsuit because
the parties are completely diverse and the amount in controversy
Chevron stated in the Notice of Removal that plaintiffs had
failed to serve defendants Laurent Oil & Gas, L.L.C., and Malloy
Energy Company, L.L.C. as of the time of removal.9 In fact,
plaintiffs served Laurent on August 6, 2013,10 and Malloy on
August 12, 2013.11 Chevron attached to the Notice of Removal the
written statements of consent to removal of the other four
parties in the lawsuit,12 but it did not allege that it had
obtained the consent of Laurent or Malloy to remove.
On September 12, 2013, plaintiffs filed this motion to
remand, arguing that Chevron's Notice of Removal is defective
because Laurent and Malloy did not consent in writing to the
R. Docs. 33-2, 33-3, 33-4, 33-5.
R. Doc. 1.
Id. at 4-5.
Id. at 5.
See R. Doc. 33-2.
See R. Doc. 33-5 at 6.
R. Doc. 1-5. The other four defendants are Noble
Energy, L.L.C., Goodrich Petroleum Company, L.L.C., Hilcorp
Energy I, L.P., and Shell Oil Company.
removal. Defendants respond that they were not required to obtain
the consent of Laurent and Malloy because those defendants were
improperly joined. Defendants also contend that, even if Laurent
and Malloy were properly joined, the "exceptional circumstances"
of this case obviated the need for their consent to remove.
Additionally, defendant Noble argues that remand is unwarranted
because, in addition to being improperly joined, Malloy was
improperly served under the Louisiana Long-Arm Statute. Chevron
seeks to amend the Notice of Removal to specify the reason for
not obtaining consent from Laurent and Malloy.
Plaintiffs reply that Chevron's failure to explain why
Laurent and Malloy did not consent to removal rendered the Notice
of Removal procedurally defective, and that Chevron cannot now
cure that defect through amendment because the thirty-day
deadline set forth by 28 U.S.C. § 1446(b) has passed. Plaintiffs
also argue that they served both Laurent and Malloy properly and
that there are no "exceptional circumstances" justifying a
departure from the usual rule that all of the defendants must
consent to removal.
At oral argument, plaintiffs' counsel conceded that
plaintiffs sued Laurent by mistake and that Laurent is not a
proper party to this case. Accordingly, the Court will limit its
analysis to whether Chevron's failure to obtain Malloy's consent
rendered the Notice of Removal defective.
General Principles of Removal
A defendant may remove a civil action filed in state court
if a federal court would have had original jurisdiction over the
lawsuit. See 28 U.S.C. § 1441(a). A district court has original
jurisdiction in cases in which the amount in controversy exceeds
$75,000, and the parties are citizens of different states. 28
U.S.C. § 1332. Removal of a case is timely if the notice of
removal is filed within thirty days of service of the initial
pleading on the defendant. 28 U.S.C. § 1446(b). (If the case is
not initially removable but later developments render it so,
removal is timely if the notice of removal is filed "within 30
days after receipt by the defendant, through service or
otherwise, of a copy of an amended pleading, motion, order or
other paper from which it may first be ascertained that the case
is one which is or has become removable." Id.) The thirty-day
limit is not jurisdictional. Getty Oil Corp. v. Ins. Co. of N.
Am., 841 F.2d 1254, 1263 (5th Cir. 1988). Nevertheless, because
removal raises significant federalism concerns, courts construe
removal requirements strictly, and "any doubt as to the propriety
of removal should be resolved in favor of remand." See Gutierrez
v. Flores, 543 F.3d 248, 251 (5th Cir. 2008) (quoting In re HotHed, Inc., 477 F.3d 320, 323 (5th Cir. 2007)); Aucoin v. Gulf S.
Pipeline Co., No. 04-CV-0284, 2004 WL 1196980, at *1 (E.D. La.
May 26, 2004); see also 17 James Wm. Moore, et al., Moore's
Federal Practice § 107.05 (3d ed. 2013) (explaining that strict
construction of the right of removal respects congressional
intent, vindicates federalism principles, and "makes good sense"
on policy grounds).
The Rule of Unanimity
In cases with multiple defendants, the Fifth Circuit
traditionally followed the first-served defendant rule, under
which all of the defendants had to join in the removal within
thirty days of the date of service on the first defendant. Getty
Oil, 841 F.2d at 1262–63. But, pursuant to a 2011 statutory
amendment adopting the last-served rule, section 1446(b) now
states that each defendant has “30 days after receipt by or
service on that defendant of the initial pleading or summons
. . . to file the notice of removal.” 28 U.S.C. §
1446(b)(2)(B).13 In other words, the thirty-day period now
extends until thirty days after the last defendant is served.
In revising section 1446(b), Congress also codified the
“rule of unanimity." See, e.g., Tilley v. Tisdale, 914 F. Supp.
2d 846, 848-49 (E.D. Tex. 2012). Under § 1446(b)(2)(A), “all
defendants who have been properly joined and served must join in
The Federal Courts Jurisdiction and Venue Clarification
Act took effect on January 6, 2012. Act of Dec. 7, 2011, Pub. L.
No. 112–63; 125 Stat. 758.
or consent to the removal of the action” to federal court. "This
does not mean that each defendant must sign the original petition
for removal," but the Fifth Circuit requires "some timely filed
written indication from each served defendant . . . that it has
actually consented to such action." Getty Oil, 841 F.2d at 1262
n.11. Although section 1446(b), as revised by the 2011 amendment,
does not explicitly mandate that all defendants consent to
removal in writing, the Court finds no indication that the Fifth
Circuit's requirement of written consent is inconsistent with or
displaced by the statutory change. Indeed, Congress's
codification of the unanimity rule signals the importance of
ensuring that all of the defendants have consented to removal.
Crowley v. Amica Mut. Ins. Co., No. 12-CV-0775, 2012 WL 3901629,
at *2 n.11 (E.D. La. Sep. 7, 2012).
Thus, if written consent on the part of all defendants is
lacking when the thirty-day removal period elapses, the notice of
removal is deemed defective and the case must be remanded. Ortiz
v. Young, 431 F. App'x 306, 307 (5th Cir. 2011); see also
Crowley, 2012 WL 3901629, at *3 ("[C]ourts applying Getty Oil
have remanded cases for lack of written consent when the
nonmoving defendants submitted affidavits attesting to their
consent after the 30-day period for removal had ended.").
The Court finds that this lawsuit must be remanded to state
court because (1) service on Malloy was proper under the
Louisiana Long-Arm Statute; (2) Chevron's Notice of Removal was
defective because it did not include Malloy's consent or explain
why Malloy's consent was unnecessary; (3) Chevron may not now
amend the Notice of Removal to cure these defects; and (4) this
case does not present exceptional circumstances that obviated the
need for Malloy's consent.
Service On Malloy Was Proper.
The Court first addresses defendant Noble's contention that
Malloy was not properly served because the citation contained an
incorrect deadline for Malloy to respond and because the
plaintiffs failed to file an affidavit of service before the case
Plaintiffs served Malloy under the Louisiana Long-Arm
Statute, La. Rev. Stat. § 13:3201, et seq. The section of that
statute entitled "Service of Process" provides in relevant part
that "a certified copy of the citation . . . and of the petition
. . . shall be sent by counsel for the plaintiff, or by the
plaintiff if not represented by counsel, to the defendant by
registered or certified mail . . . when the person is located
outside of this state . . . ." La. Rev. Stat. § 13:3204. In
compliance with this provision, plaintiff sent the citation via
certified mail to Malloy.14 Malloy received it on August 12,
2013.15 The citation states that Malloy was "summoned to comply
with the demand contained in the . . . Petitions . . . or make an
appearance either by filing a pleading or otherwise . . . within
thirty (30) days after service hereof, under the penalty of
default."16 Noble argues that this citation was deficient under
the Louisiana Long-Arm Statute because of the following
No default judgment can be rendered against the defendant
and no hearing may be held on a contradictory motion,
rule to show case, or other summary proceeding . . .
until thirty days after the filing in the record of the
affidavit of the individual who . . . [m]ailed the
process to the defendant, showing that it was enclosed in
an envelope properly addressed to the defendant, with
sufficient postage affixed, and the date it was deposited
in the United States mail, to which shall be attached the
return receipt of the defendant.
La. Rev. Stat. § 13:3205. Noble's contention is apparently that
the citation here, rather that identifying the date the affidavit
of service was filed as the date triggering the running of the
thirty-day period, improperly stated that the service itself
triggered the period.
The Court finds this argument unconvincing. Noble has not
provided -- and the Court has been unable to find -- authority
for the proposition that a citation stating that the defendant
R. Doc. 33-5 at 4-5.
Id. at 6.
Id. at 5.
must respond within thirty days of "service" is deemed void under
Louisiana law. The cases Noble cites for the proposition that
"[c]itation and service must strictly comply with the law in
order to support a valid judgment" all concern situations in
which a defendant was never served at all and hence could not be
the subject of a judgment. See Merial Ltd. v. Lagraize, 971 So.2d
403, 405-06 (La. Ct. App. 2007) (finding a service return in the
record insufficient to demonstrate that defendant had been served
because the return did "not provide the place or method of
service," as was required by statute); Willis v. Nat'l Auto.
Ins., 926 So.2d 771, 774 (La. Ct. App. 2006) (deeming judgment in
consursus proceeding invalid because several ostensible parties
to the proceeding were never served); W&R Farming P'ship v. Old
S. Props., Inc., 887 So.2d 646, 648-49 (La. Ct. App. 2004)
(holding that a party that was not served was not subject to the
jurisdiction of the trial court). Here, it is undisputed that
Malloy was served. Moreover, no court is seeking to impose a
judgment against Malloy. Merial, Willis, and W&R Farming are thus
inapposite. The Court holds that the citation served on Malloy
was not deficient.
Noble also notes that an affidavit of service was never
filed before the case was removed to federal court. It contends
that, under section 13:3205, plaintiffs' failure to file such an
affidavit means that service on Malloy was never completed and,
accordingly, that Malloy's consent to removal was not required.
Noble is incorrect. "Under the clear wording of § 3204, all
that is necessary to constitute service upon a non-resident under
the long-arm statute is that counsel for the plaintiff send a
certified copy of the citation and of the petition in the suit to
the defendant by registered or certified mail . . . ." McFarland
v. Dippel, 756 So.2d 618, 622 (La. Ct. App. 2000). "Service of
process so made has the same legal force and validity as personal
service on the defendant in this state." La. Rev. Stat.
§ 13:3204; accord Spomer v. Aggressor Int'l, Inc., 807 So.2d 267,
278 (La. Ct. App. 2001). Thus, once a plaintiff complies with
section 13:3204, service is complete, regardless of whether an
affidavit of service has been filed in the record. See CHN, Inc.
v. Mitel, Inc., 666 So.2d 1155, 1156 (La. Ct. App. 1995) (finding
that service was perfected under the Long-Arm Statute one week
before an affidavit attesting to service was filed); Bickford v.
Lutz, 339 So.2d 1268, 1270-71 (La. Ct. App. 1976) (analyzing
whether service on defendant had been perfected under section
13:3204, and then separately analyzing whether a default judgment
entered against defendant was valid under section 13:3205).
Section 13:3205 provides only that a preliminary default
judgment may not be entered until thirty days after an affidavit
of service is filed. Corte v. Cash Techs., 843 So.2d 1162, 1165-
66 (La. Ct. App. 2003). Essentially, that section concerns the
required method of proof of service for purposes of enforcing a
default judgment. Whether a defendant was served and whether the
plaintiff proved the defendant was served are distinct issues.
Section 13:3204 addresses the former, and section 13:3205 the
Other courts in this district have reached the same
conclusion, holding that, for purposes of removal deadlines,
service of process under the Louisiana Long-Arm Statute is
complete when the defendant is actually served under section
13:3204, not when the affidavit of service is filed in the state
court record. See, e.g., Kroger Co. v. Door Control Servs., Inc.,
No. 12-CV-0956, 2012 WL 4891560, at *5 (W.D. La. Oct. 15, 2012)
("In order for service to be perfected, plaintiff need only
comply with 13:3204. Section 3205 is triggered if and when
plaintiff attempts to obtain a default judgment, have a hearing
on a contradictory motion, rule to show cause, or other summary
proceeding."); see also Richoux v. CSR Ltd., No. 08-931, 2008 WL
576242, at *5 (E.D. La. Feb. 29, 2008) (expressing doubt that §
13:3205 "sets forth the requirements for the proof of proper
service in contexts, such as [removal deadlines], that are not
enumerated in its language"). Thus, if a defendant fails to
consent to removal within thirty days after it actually receives
service, the notice of removal is defective. See, e.g., Ramsay v.
Rusnak, No. 12-614, 2013 WL 4039405, at *8 (M.D. La. Aug. 7,
2013) ("[T]he rule of unanimity requires the co-defendants to
either join in the notice of removal or consent to the removal
within the applicable time period following actual service, not
filing of proof of service in state record."); Kroger Co., 2012
WL 4891560, at *5; Babin v. Isaman, No. 09-408-C, 2009 WL
3672901, at *4-5 (M.D. La. Nov. 4, 2009).
This is the better interpretation of the Louisiana Long-Arm
Statute. It respects both the statutory language, see, e.g.,
Kroger Co., 2012 WL 4891560, at *5, and the Fifth Circuit's
admonition that "any doubt as to the propriety of removal should
be resolved in favor of remand," Gutierrez, 543 F.3d at 251.
Because Malloy undisputedly received the citation and
petition for damages on August 12, 2013, the Court finds that
service was properly effected on Malloy on that date.
Chevron's Notice of Removal Is Defective.
As noted above, 28 U.S.C. § 1446(b)(2)(A) provides that "all
defendants who have been properly joined and served must join in
or consent to the removal of the action" within thirty days after
the last defendant is served. It is undisputed that Malloy did
not file a written indication consenting to removal within thirty
days after it was served. This renders Chevron's Notice of
Removal defective. Getty Oil, 841 F.2d at 1262.
Chevron now contends that Malloy's consent was unnecessary
because Malloy was improperly joined. The doctrine of improper
joinder is not strictly applicable to this case. That doctrine is
implicated when a plaintiff improperly joins an in-state party in
an effort to defeat diversity jurisdiction. See Smallwood v. Ill.
Cent. R.R. Co., 385 F.3d 568, 574 (5th Cir. 2004) ("A claim of
improper joinder by definition is directed toward the joinder of
the in-state party . . . ."). Malloy is not an in-state
defendant, and accordingly its joinder in this lawsuit could not
affect diversity jurisdiction.
But the "nominal party" doctrine, to which Chevron briefly
alludes in its opposition to the motion to remand, is potentially
applicable here. The rule that "nominal" or "formal" parties need
not consent to a notice of removal is not limited to cases where
the allegedly nominal party's presence defeats diversity
jurisdiction. See Farias v. Bexar Cty. Bd. of Trustees, 925 F.2d
866, 871 (5th Cir. 1991) (nominal parties need not join in notice
of removal even if removal is based on federal question
jurisdiction rather than diversity jurisdiction).
On these facts, however, the Court need not determine
whether Malloy is a nominal party. Even if it were, the Court
would still find Chevron's Notice of Removal defective, because
Chevron failed to explain its failure to obtain Malloy's consent.
According to 28 U.S.C. § 1446(a), a notice of removal must
"contain a short and plain statement of the grounds for
removal." Pursuant to this provision, if a removing defendant
fails to obtain the consent to remove of any codefendants, the
notice of removal must "affirmatively explain" why consent of
those defendants was unnecessary. Riggs v. Plaid Pantries, Inc.,
233 F. Supp. 2d 1260, 1267 (D. Or. 2001) (collecting cases); 14C
Charles Alan Wright, et al., Federal Practice & Procedure § 3733
(4th ed. 2013) ("[I]f unserved defendants have not joined the
notice of removal, the removing defendants should explain their
absence from that paper, in the removal notice."); see also
Courtney v. Benedetto, 627 F. Supp. 523, 526 (M.D. La. 1986).17
Otherwise, the notice of removal is deemed defective. Courtney,
627 F. Supp. at 526; see also Riggs, 233 F. Supp. 2d at 1267-68;
Mayers v. Connell, 651 F. Supp. 273, 274 (M.D. La. 1986);
Romashko v. Avco Corp., 553 F. Supp. 391, 392 (N.D. Ill. 1983)
("It is defendant's burden . . . to explain affirmatively the
absence of codefendants in the petition for removal, and failure
to set out such an explanation renders the removal petition
defective."). Here, Chevron offered no explanation for its
failure to obtain Malloy's consent.
Courtney was interpreting an older version of
§ 1446(a), which required "a short and plain statement of the
facts which entitle [the defendant(s)] to removal." The statute
was revised in 1988 to require that the grounds for removal be
stated in a "short and plain statement," but the revision was not
intended to effect any substantive change. Wright et al., supra,
§ 3733 (noting that the notice of removal still "must make the
basis for federal jurisdiction clear, and contain enough
information so that the district judge can determine whether
jurisdiction exists"); Moore, supra, § 107.30[a][I] (citing
H.R. Rep. No. 100-889, at 71 (1988)). Thus, Courtney's analysis
is still apposite.
Chevron's Motion to Amend the Notice of Removal Is Untimely.
Now, well over thirty days after Malloy (the last-served
defendant) was served, Chevron moves to amend its Notice of
Removal to add an allegation that Malloy's consent to remove was
unnecessary because Malloy was improperly joined.
"A removal petition may be amended freely within the thirty
day period set forth in 1446(b)." Aucoin, 2004 WL 1196980, at *2
(quoting Courtney, 627 F. Supp. at 527); Wright, et al., supra,
§ 3733. But the only avenue for amendment after the thirty-day
period has run is 28 U.S.C. § 1653, which provides that
"[d]efective allegations of jurisdiction may be amended, upon
terms, in the trial or appellate courts." Section 1653, "by its
terms, may only be utilized to cure defective allegations of
jurisdiction." Aucoin, 2004 WL 1196980, at *2; Wright, et al.,
supra, § 3733 (section 1653 may be used only to "set out more
specifically" a jurisdictional basis for removal "that already
ha[s] been stated, albeit imperfectly, in the original notice").
Section 1653 may not be used to cure procedural defects of the
removal, such as the failure to obtain the consent of a codefendant or the failure to explain why such consent was
unnecessary. Garner v. Hyken, No. 10-4135, 2011 WL 1002098, at *3
(E.D. La. Mar. 18, 2011) (allowing defendant to use section 1653
to amend a notice of removal to remedy a failure to obtain codefendant's consent "would undermine the Fifth Circuit's clear
rule . . . that all properly joined and served defendants must
consent to removal within thirty days of service"); Aucoin, 2004
WL 1196980, at *2 (failure to obtain co-defendant's consent is a
"substantial defect in removal proceedings" that cannot be cured
through section 1653); Courtney, 627 F. Supp. at 527
(supplemental notice of removal filed after the thirty-day time
limit could not cure an initial notice of removal that was
defective due to a failure to state the reason that not all
defendants had consented to removal); Mayers, 651 F. Supp. at
274-75 (citing Courtney for this proposition). Accordingly,
Chevron may not amend its Notice of Removal to explain its
failure to obtain Malloy's consent.
This Case Does Not Present "Exceptional Circumstances."
In Getty Oil, the Fifth Circuit noted that "exceptional
circumstances" might warrant a departure from the rigid rule that
all of the defendants must consent to removal in writing within
the thirty-day period set forth in section 1446(b). 841 F.2d at
1263 n.12. The Fifth Circuit later explained that, in most cases
in which an exception is appropriate, a defendant's lack of
consent to removal stems from dilatory tactics on the part of the
plaintiff. See Ortiz, 431 F. App'x at 307 ("[T]hose instances
where this court has exercised its equitable powers to permit a
party to consent to removal outside of the statutorily prescribed
time frame often concern plaintiff[s'] conduct, and not untimely
consent to removal by a defendant."). For example, in Gillis v.
Louisiana, 294 F.3d 755 (5th Cir. 2002), the nonremoving
defendant failed to timely file written consent into the record
because consent could be authorized only at a board meeting. Id.
at 758-59. A board meeting could not be scheduled within the
thirty-day removal period because the Board's chairman, who was
also a plaintiff in the matter, had interposed scheduling
conflicts. Id. In permitting defendants to remove, the court
nevertheless reaffirmed the standard for filing written consent
into the record set forth in Getty Oil. Id.
Gillis demonstrates that circumstances must be truly
exceptional for a court to excuse non-compliance with the
thirty-day limit. The few district courts that have found
exceptional circumstances generally confronted situations
involving bad faith, forum manipulation, and lost filings.
Turner v. Mine Safety Appliances Co., No. 01-0325, 2001 WL
456351, at *3 (E.D. La. Apr. 27, 2001) (finding no exceptional
circumstances because there was no evidence of forum manipulation
or bad faith); Prescott v. Mem'l Med. Center-Livingston, No.
9:00CV-0025, 2000 WL 532035, at *5 n.8 (E.D. Tex. Mar. 25, 2000)
Defendants complain that, at the time of removal, the state
court record indicated that no service had been made on Laurent
or Malloy. Defendants attribute this, in part, to plaintiffs'
failure to file an affidavit of service on Malloy in the state
court record. Defendants request that this Court implement a
"bright line" rule that a removing defendant need not obtain the
consent of a co-defendant with respect to whom evidence of
service has not been filed in the state court record. But that is
not the law in the Fifth Circuit; the existence of such evidence
in the record is merely one factor courts consider in determining
if exceptional circumstances are present. See, e.g., Garner, 2011
WL 1002098, at *2 (collecting cases); Bilyeu v. Johanson
Berenson,, L.L.P., No. 1:08-cv-02006, 2010 WL 1189822, at *1
(W.D. La. Mar. 26, 2010). And this Court has previously
concluded, based on an extensive survey of district court
opinions, that exceptional circumstances are generally not found
if the removing defendant merely checked the state court record
and made no effort to contact other defendants to ascertain
whether they had been served. See Garner, 2011 WL 1002098, at *2.
Chevron clearly was aware that Malloy had been sued, since
it mentioned Malloy in the Notice of Removal. And Chevron had
roughly three weeks after filing the Notice of Removal to contact
Malloy, verify that it had been served, obtain its consent to
remove, and then amend or supplement the Notice of Removal
accordingly. Chevron failed to do so. Moreover, the Court notes
that, during the period immediately following removal, Malloy was
represented by the same counsel as Goodrich, which had joined in
Chevron's Notice of Removal.18 Those counsel should have made
Compare R. Doc. 31 with R. Doc. 32.
sure that Malloy consented to Chevron's removal as well. See id.
(exceptional circumstances generally not present when codefendants are represented by the same counsel). Finally, there
is no evidence in the record that plaintiffs acted in bad faith
or otherwise impeded Chevron from obtaining Malloy's consent.
Accordingly, the Court finds that there are no exceptional
circumstances in this case that warrant a departure from the
Fifth Circuit's typical rule.
In resolving the issues presented by this motion, the Court
has been guided by the Fifth Circuit's admonition that "any doubt
as to the propriety of removal should be resolved in favor of
remand." Gutierrez, 543 F.3d at 251. For the reasons stated
above, the Court GRANTS plaintiffs' motion to remand and DENIES
Chevron's motion to amend the Notice of Removal.
New Orleans, Louisiana, this 6th day of January, 2014.
SARAH S. VANCE
UNITED STATES DISTRICT JUDGE
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