Bulik v. Arrow Realty, Inc. of Racine

This is a review of a $250,000 default judgment against Arrow Realty, Inc. of Racine (Arrow). Although Arrow raises several arguments, we hold that the case is controlled by the first issue — the effect of the failure to name Arrow in the original summons. Because personal jurisdiction is acquired by personal service of a summons naming the served party as a defendant and because Arrow was not named as a defendant in the summons, the judgment against Arrow is void.

The pertinent facts are that Evelyn G. Lui allegedly fell in the parking lot of the Rapids Drive Shopping Center in Racine,…