Micheal Hooks v. McCondichie Properties 1, Lp

CourtCourt of Appeals of Georgia
DecidedJanuary 14, 2015
DocketA14A2238
StatusPublished

This text of Micheal Hooks v. McCondichie Properties 1, Lp (Micheal Hooks v. McCondichie Properties 1, Lp) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Micheal Hooks v. McCondichie Properties 1, Lp, (Ga. Ct. App. 2015).

Opinion

FIRST DIVISION PHIPPS, C. J., ELLINGTON, P. J., and MCMILLIAN, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

January 14, 2015

In the Court of Appeals of Georgia A14A2238, A14A2333. HOOKS v. McCONDICHIE PROPERTIES JE-114, 119 1, LP et al., and vice versa.

ELLINGTON, Presiding Judge.

Michael Hooks filed this personal injury action against McCondichie

Properties 1, LP, and McCondichie Properties 2, LP, collectively (“McCondichie”)

in the Superior Court of Clayton County. He served the Secretary of State of Georgia,

and obtained a default judgment. McCondichie filed a motion to set aside the default

judgment. The trial court determined that Hooks was authorized to serve

McCondichie by substituted service upon the Secretary of State but that Hooks failed

to perfect such service in the statutorily prescribed manner. On that basis, the trial

court granted McCondichie’s motion to set aside the default judgment. Pursuant to

a granted application for an interlocutory appeal, both parties appeal. In Case No. A14A2238, Hooks contends that the trial court erred in ruling that

he failed to comply with the statutory requirements for substituted service upon a

limited partnership. In Case No. A14A2333, McCondichie contends that the trial

court erred in finding in the first instance that substituted service upon the Secretary

of State was authorized. Based on this argument, McCondichie contends that, even

if the trial court erred in ruling that Hooks failed to comply with the requirements for

substituted service, such error was moot and the order granting its motion to set aside

the default judgment nevertheless must be affirmed. For the reasons explained below,

we hold that the trial court erred in setting aside the default judgment and reverse.

Under Georgia law, when the defense of lack of personal jurisdiction due to defective service is raised by way of a motion to set aside the judgment, the trial court sits as the trier of fact. Our standard of review in this regard is the any evidence rule, and absent an abuse of discretion, we will not reverse a trial court’s refusal to set aside a judgment.

(Footnote omitted.) Stokes & Clinton, P.C. v. Noble Sys. Corp., 318 Ga. App. 497,

498 (734 SE2d 253) (2012). However, where the facts are undisputed and the

question is one of law, we review the ruling de novo. Guthrie v. Wickes, 295 Ga. App.

892, 892 (673 SE2d 523) (2009).

2 So viewed, the facts relevant to both appeals are as follows: In his complaint,

Hooks alleged that he was injured while on duty as a police officer, responding to a

burglary call at property owned by McCondichie. On August 5, 2013, Hooks sent

McCondichie a demand letter through its registered agent, James Tenney, at the

address McCondichie had provided to the Secretary of State for its registered office.

McCondichie acknowledged having received the demand letter. Further,

McCondichie’s insurer notified Hooks’ counsel that it was investigating the claim.

Hooks filed suit against McCondichie on December 12.

On December 30, 2013 and on January 6, 2014, Hook’s process server

attempted to serve the complaint on McCondichie through Tenney at the registered

office address. Neither Tenney’s name nor the name of his law firm was displayed at

that address either on the outside of the building or inside the lobby. The address was

for an executive office suite, and the receptionist at the front desk was answering calls

for several different companies. When the process server asked the receptionist to

notify Tenney that a complaint needed to be served, she took no action to call anyone;

instead, she “immediately stated that [Tenney] was ‘out of the office.’” To the process

server, the office appeared to be a “virtual office” rather than Tenney’s actual place

3 of business.1 Hooks later learned that Tenney’s principal place of business was

located at another address.2 The receptionist informed the process server that there

was no one authorized to accept service of process for Tenney or McCondichie at the

executive office suite. Hooks provided the court with a copy of the virtual office’s

standard contract, highlighting a paragraph warning clients not to use the location as

their registered office for service of process. The process server averred that, based

on his experience, further attempts to serve Tenney at that address would have been

futile.

On January 9, 2014, Hooks made substituted service upon McCondichie

through the Secretary of State and forwarded a copy of the complaint to Tenney at the

registered office address through a commercial courier service. On the same day, the

1 The executive office suite advertised was advertised as providing “virtual office packages” for mail handling and telephone answering services. 2 Hooks searched the Secretary of State’s records and discovered that the address of record for Tenney’s law firm is a private residence in Marietta and that the address listed for his principal place of business is a post office box. Although Tenney gave an affidavit averring that the registered office for McCondichie is an “active workplace” and that he “conduct[s] business” there, he did not aver that the registered office is his sole or principle place of business nor did he dispute that he has other “active workplace[s].” Further, notably absent from Tenney’s affidavit (and that of the receptionist for the virtual office) is any statement concerning the amount of time that Tenney was actually physically present in the registered office.

4 courier service attempted delivery, but was informed by the receptionist that neither

Tenney nor any employee or agent of his was present to accept the package. The

courier returned the unclaimed package to Hooks’ attorney. The courier’s affidavit

and receipt of delivery indicates that, when he attempted delivery, he was informed

by the receptionist that Tenney was not available to accept delivery. The receptionist

for the office suite stated in her affidavit that she was not employed by Tenney.

Although she has no recollection of the delivery, she stated that she would have

signed for and accepted Tenney’s mail as part of her duties as office receptionist, but

that she would have declined to accept service of process because she was not

authorized to do so.

McCondichie failed to answer the complaint, and the trial court granted Hooks

a default judgment on March 10, 2014. On March 21, 2014, McCondichie moved to

set aside and vacate the default judgment pursuant to OCGA § 9-11-60 (d) (1),

arguing that Hooks failed to properly perfect service and that, therefore, the trial court

lacked personal jurisdiction to enter the default judgment. The superior court found

that Hooks exercised reasonable diligence in attempting to serve McCondichie and

that substituted service on the Secretary of State was authorized. However, the trial

court granted the motion to open default judgment on the narrow issue that Hooks

5 failed to comply fully with OCGA § 14-9-104 (g) because forwarded process via

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Related

McClendon v. 1152 Spring Street Associates-Georgia, Ltd. III
484 S.E.2d 40 (Court of Appeals of Georgia, 1997)
Guthrie v. Wickes
673 S.E.2d 523 (Court of Appeals of Georgia, 2009)
Deal v. Coleman
751 S.E.2d 337 (Supreme Court of Georgia, 2013)
Norman Service Industries, Inc. v. Lusty
308 S.E.2d 411 (Court of Appeals of Georgia, 1983)
Stokes & Clinton, P.C. v. Noble Systems Corp.
734 S.E.2d 253 (Court of Appeals of Georgia, 2012)
Martinez v. State
750 S.E.2d 504 (Court of Appeals of Georgia, 2013)

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