In Doherty & Co. v. Goodman (1935) 294 U.S. 623, the United States Supreme Court provided guidance for determining who is a proper agent for acceptance of service on behalf of a defendant. The court concluded a specific appointment is not required, but the principal-agent relationship must be close and enduring enough to make it highly probable the defendant will receive actual notice. The plaintiff in Doherty & Co. v. Goodman was a resident of Iowa who served process on the defendant securities dealer, a resident of New York, by delivering the summons and complaint to an employee of defendant in his Des Moines office. The employee's only specific authority was to sell securities for defendant. Defendant "never ... consented that service of process upon this agent should constitute service upon himself." The Supreme Court nevertheless upheld the service under an Iowa law, which authorized service of process " 'on any agent or clerk employed in' " the office of an individual or company doing business " 'in any county other than that in which the principal resides.' " The court rejected the defendant's due process challenge to the statute. It agreed with an Iowa Supreme Court opinion which upheld the statute against a constitutional attack because " 'there is not only "reasonable probability" but practical moral certainty that the defendant will receive actual notice of the pendency of the action.' " (Doherty & Co. v. Goodman, supra, 294 U.S. at page 627.)