Samson Sales, Inc. v. Honeywell, Inc.
421 N.E.2d 522, 66 Ohio St. 2d 290, 20 Ohio Op. 3d 277 (1981)
Rule of Law:
Service of process on a corporation via certified mail is effective when sent to the corporation's usual place of business, even if not addressed to a specific officer or agent. This method is valid provided it comports with due process by being reasonably calculated to apprise the corporation of the pending action.
Facts:
- A plaintiff initiated a lawsuit against Honeywell, Inc.
- The court clerk sent the summons and complaint via certified mail to Honeywell's business office address in Cleveland.
- The envelope was addressed to the corporation, Honeywell, Inc., and not to any specific officer or agent.
- The certified mail was delivered to and signed for at Honeywell's office.
- The summons and complaint never reached the proper department or officer within Honeywell, leading the company to be unaware of the pending lawsuit.
Procedural Posture:
- A plaintiff sued Honeywell, Inc. in an Ohio Court of Common Pleas (trial court).
- After Honeywell failed to respond to the lawsuit, the trial court entered a default judgment against it.
- Honeywell filed a motion to vacate the default judgment, arguing that service of process was improper because the certified mail was not addressed to a specific corporate officer or agent.
- The Court of Appeals (intermediate appellate court) found the service to be invalid and ruled in favor of Honeywell, dismissing the plaintiff's case.
- The plaintiff, as appellant, appealed the dismissal to the Supreme Court of Ohio.
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Issue:
Does service of a summons and complaint by certified mail, addressed only to a corporation at its usual place of business and not to a specific officer or agent, satisfy the requirements for valid service of process under Ohio Civil Rule 4?
Opinions:
Majority - Clifford F. Brown, J.
Yes. Service of process by certified mail addressed to a corporation at its usual place of business is valid, even if it is not directed to a specific officer or agent. Ohio Civil Rule 4.2(6) provides three distinct and alternative methods for serving a corporation, one of which is 'by serving the corporation by certified mail at any of its usual places of business.' This language does not impose a requirement to name an individual. This method must still satisfy the constitutional due process standard from Mullane v. Central Hanover Bank & Trust Co., which requires notice that is 'reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action.' Sending notice to Honeywell's established business address met this standard. The failure of the documents to reach the correct internal department was a result of Honeywell's own mail handling procedures, not a defect in the method of service itself.
Analysis:
This decision clarifies that the plain language of Ohio's procedural rules for service on a corporation will be enforced, prioritizing substance over formalistic requirements like naming a specific individual. It firmly places the burden on corporations to implement reliable internal mail-handling procedures to ensure legal notices are properly routed. The ruling reinforces the principle that as long as the method of service is constitutionally sound—meaning it's reasonably calculated to provide notice—a party's internal mishandling will not invalidate the service. This outcome simplifies the process for plaintiffs suing corporations while holding corporate defendants responsible for their own internal logistics.
