Cardenas v. City of Chicago, 646 F.3d 1001

Officer Gallegos led a search warrant execution at the Cardenas residence, entering without knocking or announcing and handling residents harshly; warrant did not authorize no-knock entry; plaintiffs allege unlawful search, assault, and related claims; service of process on Gallegos was improper and occurred long after the 120-day deadline; removal to federal court occurred and plaintiffs later sought to serve Gallegos; district court dismissed for insufficient service and lack of good cause, then with prejudice due to expiration of the statute of limitations; City dismissed as no liability without officer present; appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service on Gallegos was timely and proper.	Cardenas argues proper service occurred within 120 days.	Gallegos argues service was inadequate and untimely.	No, service was insufficient and untimely.
Whether the district court abused its discretion in denying a discretionary extension for service.	Plaintiffs contend factors support an extension.	City/Gallegos argue failure to serve and inaction justify dismissal.	No, court did not abuse discretion; dismissal affirmed.

Ligas v. 549 F.3d 497, 549 F.3d 497 (7th Cir. 2008) (standard for abuse-of-discretion review in Rule 4(m) extensions)
Panaras v. Liquid Carbonic Indus. Corp., 94 F.3d 338 (7th Cir. 1996) (consideration of statute of limitations in extension analysis)
Coleman v. Milwaukee Bd. of Sch. Dirs., 290 F.3d 932 (7th Cir. 2002) (discipline for discretionary decision under Rule 4(m))
Troxell v. Fedders of N. Am., Inc., 160 F.3d 381 (7th Cir. 1998) (emphasizes discretion in Rule 4(m) determinations)
Romo v. Gulf Stream Coach, Inc., 250 F.3d 1119 (7th Cir. 2001) (timing of removal and service interplay under Rule 4(m))
uBID, Inc. v. GoDaddy Grp., Inc., 623 F.3d 421 (7th Cir. 2010) (de novo review standard for service of process)