Kenneth Slate v. The Health and Hospital Corporation of Marion County, Indiana, Public Health Division (mem. dec.), 49A02-1603-OV-681

HHC cited Litton Mortgage Servicing Center for exterior property code violations at 4352 N. Kitley Ave.; citation and $100 fine issued after inspections in 2013 and 2014.
HHC sued on November 12, 2014, seeking compliance and a permanent injunction; service was made on Litton’s registered agent, Kenneth Slate, who lived at the property.
At the December 23, 2014 hearing Slate appeared pro se, discussed his connection to the property, admitted receiving notices as registered agent, and testified he had removed some debris but could not finish cleanup.
The trial court entered judgment for HHC: ordered Slate to pay the $100 fine, issued a cleanup order and lien, and entered a permanent injunction prohibiting future violations.
Over a year later Slate filed a T.R. 60(B)(6) motion arguing the judgment was void for lack of personal jurisdiction and for violation of Due Process due to allegedly late notice; the trial court denied the motion and Slate appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court had personal jurisdiction over Slate	HHC: Slate appeared and participated at the hearing and never objected, so he submitted to jurisdiction	Slate: He was compelled to attend, lacked counsel and time to prepare, and therefore never consented to jurisdiction	Court: Appearance and participation without timely objection waived any personal-jurisdiction challenge; no void judgment on that ground
Whether Slate was denied due process by inadequate notice	HHC: Slate received actual notice and an opportunity to be heard at the hearing; he did not move for continuance or show prejudice	Slate: Sheriff left summons at his door; he found papers only the day before and lacked time to prepare, so notice was constitutionally inadequate	Court: Actual receipt and opportunity to present objections satisfied Mullane; Slate did not show he would have acted differently, so no voiding for due-process failure

LinkAmerica Corp. v. Cox, 857 N.E.2d 961 (Ind. 2006) (personal-jurisdiction standards and waiver by appearance)
Thomison v. IK Indy, Inc., 858 N.E.2d 1052 (Ind. Ct. App. 2006) (review standard for personal jurisdiction questions)
Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) (due process requires notice reasonably calculated to apprise interested parties and opportunity to be heard)
World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (due-process limits on personal jurisdiction and related principles)
Stidham v. Whelchel, 698 N.E.2d 1152 (Ind. 1998) (T.R. 60(B)(6) timeliness for void-judgment claims)