Spudnuts, Inc. v. Lane
In Spudnuts, Inc. v. Lane, 139 Ariz. 35, 37, 676 P.2d 669, 671 (App. 1984) the trial court had granted a post-judgment motion to amend the pleadings to add an additional party-defendant. 139 Ariz. at 35, 676 P.2d at 669.
On appeal, we observed that "'the party to be added must be properly brought before the court or no judgment can be entered or enforced.'" Id. at 36, 676 P.2d at 670.
The Court reversed the judgment, concluding the additional defendant could not be subjected to liability without violating due process because "the court does not obtain jurisdiction over the person" where "service of process does not comply with the statutory requirements." Id. at 37, 676 P.2d at 671.