New York Court of Appeals
Fashion Page, Ltd., Respondent v. Zurich Insurance Company, Appellants, Defendants
April 29, 198050 N.Y.2d 265
Summary
The Court affirmed that service of process on Zurich Insurance was proper when the summons was delivered to the corporation's executive secretary, who was identified by the company's own employees as authorized to accept service. The Court held that a corporation may implicitly appoint an agent for service without a formal written designation under CPLR 318, and that reasonable reliance on the corporation's employees satisfies the statutory purpose of CPLR 311(1). Justice Gabrielli concurred separately, arguing that service should hinge on actual delivery to an authorized person rather than the server's reasonableness.