ACOA: Summons Invalid for Omitting Defendant Name in “Directed to”


Union Pac. R.R. Co. v. Skender, 2016 Ark. App. 206, 489 S.W.3d 176 (2016).

Arkansas Court of Appeals ruled that employee’s summons in his Federal Employees’ Liability Act suit against employer was invalid.

The “directed to” portion of the summons only referred to the name and address of the agent for service. It did not include the name or address of the defendant.

Summons did not comply with the requirement in Rule 4(b) of the Arkansas Rules of Civil Procedure that it be directed to the defendant.

Opinion date: April 13, 2016.