Supreme Judicial Court of Maine
Wallace R. Brown v. Jeffrey A. Thaler
June 22, 20052005 Me. LEXIS 81
Summary
The Maine Supreme Judicial Court affirmed the Superior Court’s dismissal of Brown’s complaint for insufficient service of process. The Court held that mailing the summons and complaint without the required acknowledgment form does not satisfy M.R. Civ. P. 4(c)(1), and therefore no personal jurisdiction was obtained. The decision was reviewed de novo.
Holding
- Did service by certified mail without the required acknowledgment form satisfy Maine Rule 4(c)(1) and thus confer personal jurisdiction?. No; service was insufficient because the acknowledgment form was not returned, so personal jurisdiction was not obtained and the complaint was properly dismissed.
Cited authorities
- Rule 4(c)(1) of the Maine Rules of Civil Procedure