Varela v. Flintlock Construction, Inc.
The plaintiff, Norma Varela, filed a complaint in New York Supreme Court, Bronx County, against Flintlock Construction, Inc. and Gregory Steck, alleging sexual harassment, unlawful discharge, and discrimination. An amended complaint filed seven years later added Andrew Weiss as a defendant, who subsequently filed a notice of removal to the District Court. Varela moved to remand the case to state court, arguing Weiss's removal petition was untimely. The District Court, presided over by Judge COTE, analyzed whether the 30-day removal period runs from the first-served defendant or the last-served defendant. The court adopted the 'last-served defendant rule,' consistent with the Supreme Court's Murphy Brothers decision, concluding that Weiss's removal petition was timely as it was filed within 30 days of him being served with the amended complaint.