4:25-cv-00298
N.D. Tex.Jul 7, 2025Background
- Plaintiff Lilian Onoh sought court authorization to serve process on Sahara Reporters Media Group Inc. ("Sahara") and La Kiesha Landrum-Pierre via email after unsuccessful attempts at personal service.
- Onoh claims Landrum-Pierre is Sahara’s Chief Executive Officer and identified four email addresses via a skip trace for possible service.
- The attempts to serve Landrum-Pierre at a physical address were unsuccessful, with the mailbox at the address bearing a different name (“The Reeds”).
- Onoh provided documents suggesting Landrum-Pierre’s past affiliation with Sahara but no conclusive evidence she is currently an officer or registered agent.
- No evidence was presented that the email addresses had been used by the defendants recently, nor that other methods of service (like mail or service on a registered agent/Secretary of State) were attempted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authorization for email service | Landrum-Pierre is CEO and email is necessary after failed personal service. | Not specified. | Denied—insufficient evidence of recent email usage or role. |
| Sufficiency of efforts for service | Multiple personal attempts and skip tracing justify substituted service. | Not specified. | Denied—traditional and statutorily allowed service lacking. |
| Appropriateness of email as notice | Email addresses are still in use; postings gave support. | Not specified. | Denied—no evidence of recent use within past three months. |
| Proper party for corporate service | Landrum-Pierre can accept service for Sahara. | Not specified. | Denied—no evidence she’s current officer/registered agent. |
Key Cases Cited
- State Farm Fire and Cas. Co. v. Costley, 868 S.W.2d 298 (Tex. 1993) (substituted service is only permitted where there is evidence that such service would be reasonably effective to provide notice)