CUC Properties VI, L.L.C. v. Smartlink Ventures, Inc.

Citations

• 178 N.E.3d 556
• 2021 Ohio 3428

Syllabus

CERTIFIED MAIL – SIGNATURE – PANDEMIC – RETURN RECEIPT – CIV.R. 4.1 – SERVICE OF PROCESS - JURISDICTION: Service of process was not effective under Civ.R. 4.1(A)(1)(a) where the mail carrier signed the certified mail receipt on behalf of the recipient due to the Covid-19 pandemic, in contravention of United States Postal Service guidelines, and there was no order permitting the postal employee's signature to constitute proper service on the defendant in light of the pandemic. Therefore, the trial court never acquired personal jurisdiction over the defendant and lacked jurisdiction to enter a default judgment against it.