Service Of Process On A Corporation In California.

Our Code of Civil Procedure provides a number of ways to serve process on a corporation doing business in the state. The most common method is by service on the corporation’s designated agent for service of process. (Code of Civil Procedure section 416.10, subdivision (a).) Otherwise, a corporation may be served by personally delivering a summons and complaint to those corporate officers, managers and employees identified in section 416.10, subdivision (b), or by delivering process to someone in charge of the office of one of the individuals identified in section 416.10, subdivision (b) and then mailing the individual a copy of the summons and complaint. (Civ.Proc. § 415.20.) In the present case, plaintiff simply left a summons and complaint with someone who was not identified on the proof of service and who was in charge of a branch office of the defendant corporation and then mailed a copy of the summons and complaint to the corporation, rather than any individual officer or manager. Plaintiff thereafter obtained a default against the corporation and a $254,000 default judgment. The trial court later set aside both the entry of default and the default judgment. Noting that strict compliance with the code’s provisions for service is not required, and also that a corporation can only be served through service on some individual person, the appellate court agreed with the trial court that service was defective because plaintiff did not show substantial compliance, and affirmed setting aside the default. (Ramos v. Homeward Residential, Inc. (Cal. App. Fourth Dist., Div. 1; February 20, 2014) 223 Cal.App.4th 1434, [168 Cal.Rptr.3d 114].)