Harris v. Maready

Justice MARTIN

dissenting in part.

I concur in parts II and III of the majority opinion. For the reasons herein stated, I am compelled to dissent from part I of the opinion.

The majority leaves the well-defined path of determining the validity of service of process as set forth in Philpott v. Kerns, 285 N.C. 225, 203 S.E. 2d 778 (1974), and other cases, and embarks upon the uncertain and uncharted waters of whether there is a “substantial possibility of confusion in this case about the identity of Maready as a party being sued” as the test for sufficiency of service. In making this departure, the majority relies principally upon Wiles v. Construction Co., 295 N.C. 81, 243 S.E. 2d 756 (1978). In Wiles, the summons was directed to the defendant corporation’s registered agent rather than to the corporation. This Court felt “that the time has come to re-evaluate the considerations on which this narrow interpretation of sufficiency of process on corporate defendants is grounded.” Id. at 84, 243 S.E. 2d at 757. Further, the Court stated:

[W]e feel that the better rule in cases such as this is that when the name of the defendant is sufficiently stated in the caption of the summons and in the complaint, such that it is clear that the corporation, rather than the officer or agent receiving service, is the entity being sued, the summons, *553when properly served upon an officer, director or agent specified in N.C.R. Civ. P. 4(j)(6), is adequate to bring the corporate defendant within the trial court’s jurisdiction.

Id. at 85, 243 S.E. 2d at 758 (emphasis added).

It is readily apparent that the Court strictly limited Wiles to the facts of that case, where service is attempted on a corporate defendant. The majority seeks to extend the holding of Wiles to individuals. It so happens that the defendant in the present case is a lawyer, but the opinion is not limited to lawyers. Rather, the opinion would grant jurisdiction over the person of anyone if there is no substantial possibility of confusion about the identity of the person being sued, even though the attempted service was not in accord with the statute. This abrogates an essential requirement for valid service as contained in Rule 4(b) of the North Carolina Rules of Civil Procedure and leaves counsel and the courts with no fixed rule for determining the validity of service. Rule 4(b) requires that the summons be directed to the defendant and that he be notified to appear and answer within thirty days after service. Rule 4(j)(l)(a) requires that to obtain service upon a natural person a copy of the summons must be delivered to the defendant. (Emphasis added.) There are substantial reasons that the copy of the summons be directed to defendant. By so doing, he knows that he is required to appear and answer. A summons directed to another party or person would not place the defendant on notice that he is required to take action. As the summons is not directed to him, a defendant could assume that only the person to whom the summons is directed is required to appear and answer. By not delivering to Maready a copy of the summons directed to him, plaintiff has failed to comply with the statute.

It is the rule of this Court that unless individual natural persons are served with summons in strict accord with the statute, the service is constitutionally invalid. Such service does not give the court jurisdiction. Philpott v. Kerns, supra, 285 N.C. 225, 203 S.E. 2d 778; Distributors v. McAndrews, 270 N.C. 91, 153 S.E. 2d 770 (1967). “ ‘Actual notice, given in any manner other than that prescribed by statute cannot supply constitutional validity to the statute or to service under it.’ ” McAndrews, 270 N.C. at 94, 153 S.E. 2d at 772. Neither Philpott nor McAndrews was overruled, either expressly or impliedly, by Wiles.

*554Moreover, Wiles has been on the books since 1978 and the legislature has not amended N.C.R. Civ. P. 4 to adapt to Wiles. While it is true that the conduct of a lawsuit is not a game between counsel, the party seeking jurisdiction over a defendant has the burden of providing sufficient process for that purpose. Here, the plaintiff, represented by counsel, failed to so do with respect to the defendant Maready.

The facts in Stone v. Hicks, 45 N.C. App. 66, 262 S.E. 2d 318 (1980), are indistinguishable from those in the Maready case. In Stone, the copy of the summons delivered to the defendant Hicks directed the defendant Fowler to appear and answer; the copy delivered to defendant Fowler directed the defendant Hicks to appear. The Court of Appeals held that the service was fatally defective and that no jurisdiction over the defendants was obtained.

In Neal-Millard Company v. Owens, 115 Ga. 959, 42 S.E. 266 (1902), the Supreme Court of Georgia held that service on a defendant with process commanding someone else to appear is no process at all as to the defendant and he would have the right to utterly disregard it.

It is conceded that the service on Maready was not as prescribed by the statute. The summons served upon Maready was not directed to him as required by N.C.R. Civ. P. 4(b). Without statutory process, the court acquires no jurisdiction over defendant. Beaufort County v. Mayo, 207 N.C. 211, 176 S.E. 753 (1934). “Law is not a ‘feather on the water’ and it should not be ‘quicksand’ to trap the unwary.” Id. at 214, 176 S.E. at 755. Not only was the attempted service unauthorized by law, it was contrary to law, N.C.R. Civ. P. 4(b), and the court did not acquire jurisdiction. 62 Am. Jur. 2d Process § 30 (1972). Moreover, the service is constitutionally invalid, preventing the court from obtaining jurisdiction over Maready. Philpott, supra; McAndrews, supra; Stone, supra.

This is a hard case, and hard cases tend to make bad law. The law has established one rule for all persons. I cannot concur in the new general rule for service of process which the majority seeks to adopt.

*555I vote to affirm the Court of Appeals in affirming the dismissal of the claim against defendant Maready for insufficiency of service.

Chief Justice BRANCH joins in this dissenting opinion.