Padigos v. Padigos

CourtSuperior Court of Guam
DecidedAugust 20, 2012
DocketDM0113-11
StatusUnknown

This text of Padigos v. Padigos (Padigos v. Padigos) is published on Counsel Stack Legal Research, covering Superior Court of Guam primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Padigos v. Padigos, (superctguam 2012).

Opinion

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5 IN THE SUPERIOR COURT OF GUAM

6 ILDEFONSO PADIGOS, ) DOMESTIC CASE NO. DMOl13-11 7 ) 8 Plaintiff, ) ) DECISION AND ORDER 9 v. ) ) 10 SHEIRILL ZUNIGA VERGARA PADIGOS, ) II ) Defendant. ) 12

13 INTRODUCTION 14 This matter came before the HONORABLE ARTHUR R. BARCINAS on the 13th day 15 of April, 2012, for hearing on Plaintiffs request for the entry of default judgment against the 16

17 Defendant. Attorney Vanessa Ji represented the Plaintiff, and the Defendant has not yet been

18 served, nor made an appearance. The Court now issues the following Decision and Order on 19 the matter. 20 DISCUSSION 21

The issue of personal jurisdiction arises in this case because the Plaintiff has requested 22

23 that default judgment be entered based upon the previously obtained order(s) of the Court

24 allowing service upon the Defendant through publication and mailing. 25 A) Personal Jurisdiction 26 A comi must have jurisdiction over a defendant's person, his or her property, or the res 27

28 which is the subject of the suit; further, the defendant must be amenable to and must receive Decision and Order Domestic Case No. DMO 113-11; Padigos v. Padigos

service of process. These are the concepts that embody personal jurisdiction and service. A

2 court may not enter a valid judgment in the absence of the proper exercise of personal

3 jurisdiction. Pennoyer v. Neff, 95 U.S. 714, 716 (1877)("said judgment is in personam, and 4 appears to have been given without the appearance of the defendant in the action, or personal 5 service of the summons upon him, and while he was a non-resident of the State, and is, 6 therefore, void"); New York Life Insurance Co. v. Dunlevy, 241 U.S. 518, 522-23 (1916); 7

8 Hansberry v. Lee, 311 U.S. 32, 40 (1940)("It is a principle of general application in Anglo-

9 American jurisprudence that one is not bound by a judgment in personam in a litigation ... to 10 which he has not been made a party by service of process."). II Traditionally, personal jurisdiction was based on the defendant's actual presence within 12

the territorial power of a particular court. However, in more recent jurisprudence, the defendant 13

14 need only have sufficient contacts with the forum so that the maintenance of a suit against him

15 or her in a jurisdiction does not "offend traditional notions of fair play and substantial justice." 16 International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945). The purpose of the minimum 17 contacts test "is to protect a defendant from the travail of defending in a distant forum, unless 18

19 the defendant's contacts with the forum make it just to force him to defend there." Phillips

20 Petroleum Company v. Shutts, 472 U.S. 797, 807-808 (1985). 21 In addition to establishing minimum contacts (or jurisdiction over the res of the suit), 22 before a court may exercise its power of personal jurisdiction over a defendant, the procedural 23 requirement of service of summons must be satisfied. "[S]ervice of summons is the procedure 24

25 by which a court having venue and jurisdiction of the subject matter of the suit asserts

26 jurisdiction over the person of the party served." Mississippi Publishing Corp. v. Murphree, 326 27

Page 2 of25 Decision and Order Domestic Case No. DMOl13-11; Padigos v. Padigos

U.S. 438, 444-45 (1946); see also Robertson v. Railroad Labor Bd., 268 U.S. 619, 622-23

2 (1925).

3 Prior to 1993, three prerequisites needed to be satisfied before a court could exercise 4 personal jurisdiction over a non-resident defendant; 1) a constitutionally sufficient relationship 5 must exist between the defendant and the forum; 2) a basis for the defendant's amenability to 6 service of summons must exist; and 3) the procedural requirement of service of summons must 7

8 be satisfied by notice to the defendant. Omni Capital Intern., Ltd. v. Rudolf Wolff & Co., Ltd.,

9 484 U.S. 97, 103-104, and n.6 (1987). 10 In 1987, in Omni Capital International v. Rudolf Wolff & Company, Ltd., the Supreme II Court held that international service on a foreign defendant under the Commodities Exchange 12

Act, which was silent on service in a foreign country at the time, was ineffective under former 13

14 Rule 4(h), due to lack of amenability to service. The Court held:

15 [B]efore a court may exercise personal jurisdiction over a defendant, there must 16 be more than notice to the defendant and a constitutionally sufficient relationship between the defendant and the forum. There also must be a basis for the 17 defendant's amenability to service of summons. Absent consent, this means there must be authorization for service of summons on the defendant. Thus, under Rule 18 4(e), a federal court normally looks either to a federal statute or to the long-arm 19 statute of the State in which it sits to determine whether a defendant is amenable to service, a prerequisite to its exercise of personal jurisdiction. 20 Id. at 104-105. 21

22 "Amenability," therefore, means the existence of an explicit federal proVIsIon for

23 international service or the existence of a state long-arm statute which authorizes such service. 24 See Id.; and Mwani v. bin Laden, 417 F.3d 1,8-9 (D.C. Cir. 2005). 25 However, "amenability" to service, even for foreign residents, has been substantively 26 eliminated as an issue in cases under the Federal Rules of Civil Procedure, because in 1993, the 27

28 Advisory Committee on Civil Rules replaced the former Federal Rule Rule 4(i) with what is

Page 3 of25 Decision and Order Domestic Case No. DMO 113-11; Padigos v. Padigos

now Rule 4(f). Subdivision (f) of Rule 4 is a comprehensive provision for service of a summons

2 and complaint on individuals residing in a foreign country. The history of the rule, the Practice

3 Notes and the 1993 Advisory Committee Notes indicate that the new Rule 4(f) was drafted in 4 response to the United States Supreme Court's decision in Omni Capital International, such that 5 its enactment would nullify Omni's amenability requirement that there be explicit authorization 6 by state or federal law for service outside the United States. According to the Note of the 7

8 Advisory Committee: "[g]iven the substantial increase in the number of international

9 transactions and events that are the subject of litigation in federal courts, it is appropriate to 10 infer a general legislative authority to effect service on defendants in a foreign country." II Advisory Committee on Civil Rules, Note to Subdivision (f) (1993). The texts of Rule 4(f) and 12

(k) facilitate the use of state long-arm statutes to assert jurisdiction over defendants who cannot 13

14 be served under state law, but who can be constitutionally subjected to the jurisdiction of a

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Related

Pennoyer v. Neff
95 U.S. 714 (Supreme Court, 1878)
New York Life Insurance v. Dunlevy
241 U.S. 518 (Supreme Court, 1916)
Robertson v. Railroad Labor Board
268 U.S. 619 (Supreme Court, 1925)
Yarborough v. Yarborough
290 U.S. 202 (Supreme Court, 1933)
Davis v. Davis
305 U.S. 32 (Supreme Court, 1938)
Hansberry v. Lee
311 U.S. 32 (Supreme Court, 1940)
Williams v. North Carolina
325 U.S. 226 (Supreme Court, 1945)
International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
Coe v. Coe
334 U.S. 378 (Supreme Court, 1948)
Estin v. Estin
334 U.S. 541 (Supreme Court, 1948)
Phillips Petroleum Co. v. Shutts
472 U.S. 797 (Supreme Court, 1985)
Volkswagenwerk Aktiengesellschaft v. Schlunk
486 U.S. 694 (Supreme Court, 1988)
Burnham v. Superior Court of Cal., County of Marin
495 U.S. 604 (Supreme Court, 1990)
Mwani, Odilla Mutaka v. Bin Ladin, Usama
417 F.3d 1 (D.C. Circuit, 2005)
J. McIntyre Machinery, Ltd. v. Nicastro
131 S. Ct. 2780 (Supreme Court, 2011)

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