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Reiner v. Pittsburg Des Moines Corp.

Citations: 35 Wash. App. 331; 666 P.2d 396; 1983 Wash. App. LEXIS 2588Docket: No. 4975-2-III

Court: Court of Appeals of Washington; July 12, 1983; Washington; State Appellate Court

Narrative Opinion Summary

In this case, the plaintiff filed a personal injury lawsuit against a foreign corporation, Burns, Roe, Inc., after sustaining injuries. The primary legal issue revolved around the sufficiency of service of process under RCW 4.28.080(10), which requires delivery to a corporate agent. The summons and complaint were initially delivered to the spouse of the corporation's designated agent, who subsequently gave them to the agent. The trial court dismissed the case for insufficient service. However, the Supreme Court reversed this decision, finding that the service substantially complied with statutory requirements and effectively notified the corporation of the lawsuit without causing prejudice. The court reinforced the doctrine of substantial compliance, highlighting the fulfillment of statutory purposes over rigid adherence to procedural technicalities. The decision emphasizes the significance of practicality in legal processes to prevent procedural hurdles from obstructing justice. The case was remanded for trial, allowing the plaintiff's claims to proceed. The ruling underscores the judiciary's preference for substance over formality in interpreting service statutes to safeguard access to justice.

Legal Issues Addressed

Interpreting Service Statutes to Avoid Procedural Obstacles

Application: The court emphasized a practical approach to service statutes to prevent unnecessary procedural barriers that could impede justice.

Reasoning: The Supreme Court's approach emphasizes the importance of factual realities over strict technicalities. If RCW 4.28.080(10) is interpreted rigidly, it could force Mr. Reiner to refile his action, wasting resources, or potentially prevent him from pursuing his claim due to time limits.

Service of Process on Agents for Foreign Corporations

Application: Service of process was deemed valid when the documents reached the designated agent, fulfilling statutory requirements despite initial delivery to the agent's spouse.

Reasoning: Therefore, service was considered valid under RCW 4.28.080(10), affirming that both substantial and actual compliance were achieved.

Substantial Compliance with Service of Process Statutes

Application: The court held that substantial compliance with service of process statutes is adequate when the purpose of the statute is fulfilled and no prejudice occurs to the opposing party.

Reasoning: The doctrine of substantial compliance, previously established in case law, is applicable, indicating that strict compliance is not necessary as long as the purpose of the statute is fulfilled and no prejudice to the opposing party occurs.