Dill v. Berquist Construction Co.
California Court of Appeal
29 Cal. Rptr. 2d 746 (1994)
Dill (plaintiff) mailed his summons and complaint against out-of-state corporate defendants Berquist and Strata directly to each company's address without naming any specific individual, and unidentified employees (not shown to be corporate officers or authorized agents) signed the return receipts; after obtaining a $200,000 default judgment when neither corporation responded, the corporations moved to dismiss on the ground they were never validly served under California's corporate-service statute, and the trial court granted the motion.
Whether, under California law, if there is substantial compliance with the service rules for a complaint, proof that the correct statutory person actually received the complaint is still necessary.