National Equipment Rental, Ltd. v. Szukhent
Encyclopedia
National Equipment Rental, Ltd. v. Szukhent, 375 U.S. 311
(1964), was a case in which the Supreme Court of the United States
held that service of process upon a party's designated agent does not invalidate personal jurisdiction that would otherwise be established, if the agent gives prompt notice to the party.
relationship with plaintiff National Equipment Rental, a New York-based company, for the leasing
of farm equipment. This contract, written by National Equipment Rental, included a term designating Florence Weinberg, at a New York address, as agent
for service of process
regarding the contract. The Szukhents had never met Ms. Weinberg. In suing the Szukhents in Federal court (E.D.N.Y.), National Equipment Rental served process upon Ms. Weinberg, who then notified the Szukhents of the suit via mail. Subject-matter jurisdiction was founded upon diversity of citizenship. The Szukhents challenged personal jurisdiction on the grounds that there was no constitutional basis for personal jurisdiction.
With effective service, the Court held that personal jurisdiction over the Szukhents had been established in the District Court, pursuant to the then-effective Federal Rule of Civil Procedure
4(d)(1).
Justice Black dissented, and would have found the agency relationship invalid by applying of New York state appellate court precedent, thus affirming the District Court's quashing of service. Alternatively, if defining agency law for the purposes of the Federal Rules of Civil Procedure, Justice Black would not include the relationship in question in such a definition. Finally, Justice Black questioned whether the Szukhents had received due process under the Fifth and Fourteenth Amendments, which form parts of the basis for Constitutional personal jurisdiction jurisprudence.
Justice Brennan, with whom the Chief Justice and Justice Goldberg joined, agreed with Justice Black's second contention, and would have held that 4(d)(1) requires a Federal standard for agency, and that the relationship with Ms. Weinberg would not meet such requirements.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1964), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that service of process upon a party's designated agent does not invalidate personal jurisdiction that would otherwise be established, if the agent gives prompt notice to the party.
Background
Defendants Szukhents, farmers in Michigan, entered into a contractualContract
A contract is an agreement entered into by two parties or more with the intention of creating a legal obligation, which may have elements in writing. Contracts can be made orally. The remedy for breach of contract can be "damages" or compensation of money. In equity, the remedy can be specific...
relationship with plaintiff National Equipment Rental, a New York-based company, for the leasing
Lease
A lease is a contractual arrangement calling for the lessee to pay the lessor for use of an asset. A rental agreement is a lease in which the asset is tangible property...
of farm equipment. This contract, written by National Equipment Rental, included a term designating Florence Weinberg, at a New York address, as agent
Law of agency
The law of agency is an area of commercial law dealing with a contractual or quasi-contractual, or non-contractual set of relationships when a person, called the agent, is authorized to act on behalf of another to create a legal relationship with a third party...
for service of process
Service of process
Service of process is the procedure employed to give legal notice to a person of a court or administrative body's exercise of its jurisdiction over that person so as to enable that person to respond to the proceeding before the court, body or other tribunal...
regarding the contract. The Szukhents had never met Ms. Weinberg. In suing the Szukhents in Federal court (E.D.N.Y.), National Equipment Rental served process upon Ms. Weinberg, who then notified the Szukhents of the suit via mail. Subject-matter jurisdiction was founded upon diversity of citizenship. The Szukhents challenged personal jurisdiction on the grounds that there was no constitutional basis for personal jurisdiction.
Opinion of the Court
The Supreme Court upheld the ability of parties to a contract to agree in advance to the jurisdiction of a particular court. The Court then proceeded to consider the validity of the agency relationship between Ms. Weinberg and the Szukhents, and found that since Ms. Weinberg appropriately notified the Szukhents, the agency was valid under relevant laws, and therefore the service upon Ms. Weinberg was effective service upon the Szukhents.With effective service, the Court held that personal jurisdiction over the Szukhents had been established in the District Court, pursuant to the then-effective Federal Rule of Civil Procedure
Federal Rules of Civil Procedure
The Federal Rules of Civil Procedure govern civil procedure in United States district courts. The FRCP are promulgated by the United States Supreme Court pursuant to the Rules Enabling Act, and then the United States Congress has 7 months to veto the rules promulgated or they become part of the...
4(d)(1).
Justice Black dissented, and would have found the agency relationship invalid by applying of New York state appellate court precedent, thus affirming the District Court's quashing of service. Alternatively, if defining agency law for the purposes of the Federal Rules of Civil Procedure, Justice Black would not include the relationship in question in such a definition. Finally, Justice Black questioned whether the Szukhents had received due process under the Fifth and Fourteenth Amendments, which form parts of the basis for Constitutional personal jurisdiction jurisprudence.
Justice Brennan, with whom the Chief Justice and Justice Goldberg joined, agreed with Justice Black's second contention, and would have held that 4(d)(1) requires a Federal standard for agency, and that the relationship with Ms. Weinberg would not meet such requirements.