Ralph's Concrete Pumping, Inc. v. Concord Concrete Pumps, Inc.

¶1 At issue is whether service of process by mail on a foreign corporation pursuant to Superior Court Civil Rule (CR) 4(i)(l)(D) is sufficient to confer personal jurisdiction in Washington courts where personal service under the long-arm statute, RCW 4.28.185, was not made. Because CR 4 conditions service under that court rule on a statute providing for foreign service that contains “no provision prescribing the manner of service” and the long-arm statute expressly provides for personal service, service under CR 4 was not authorized here. Moreover, Ralph’s Concrete Pumping Inc. failed to make…