Master Capital Solutions Corp. v. Sergio Rene Sanchez Araujo, Lorena Armida Beltran Juarez and Grupo Promotor Setresa S. De RL. De C v., 456 S.W.3d 636

Appellees sued Master Capital (a foreign corporation) for failing to fund a $3.65 million real estate loan and elected service by certified mail to an Illinois address.
The return of service included a signed return receipt bearing the name "Amber Johnson." The petition did not identify any individual agent for Master Capital.
Appellees obtained a default judgment after Master Capital failed to answer. Master Capital then moved for a new trial, admitting it had received lawsuit-related documents but asserting its failure to answer was unintentional and that it believed it would be dismissed.
At the new-trial hearing, Appellees’ counsel asserted there was "no issue as to notice and service" and argued Master Capital knew of the suit; the trial court denied the motion.
On appeal, Master Capital argued the default judgment was void due to defective service: Appellees failed to designate an agent and the return receipt did not show Amber Johnson was an authorized agent to accept service.
The Court of Appeals reversed and remanded, holding the record failed to show strict compliance with service requirements because it did not establish Amber Johnson’s authority to accept service on behalf of Master Capital.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service by certified mail was effective on a corporation	Service receipt signed by "Amber Johnson" shows Master Capital was served	Service was defective because Amber Johnson is not shown to be an authorized agent and petition did not name an agent	Service was invalid; record fails to show delivery to an agent authorized to accept service
Whether defendant waived challenge to service by admitting receipt of suit papers	Master Capital conceded service at new-trial hearing and in filings; thus waived complaint	Admissions were only of receipt/knowledge, not that service was "duly" made under procedural rules	No waiver: conclusory admissions of receipt did not bind Master Capital as to strict-service compliance
Whether actual notice can cure defective service for default-judgment jurisdiction	Appellees: actual notice and defendant’s conduct show no prejudice; judgment valid	Actual notice alone cannot confer jurisdiction when service was not proper	Actual notice insufficient; strict compliance required for default judgments
Whether default judgment should be set aside under Craddock factors	N/A (appellees asserted defendant knew and failed to answer)	Master Capital argued Craddock factors and also raised service defect on appeal	Court did not rely on Craddock relief; reversed based on defective service of process

Craddock v. Sunshine Bus Lines, Inc., 133 S.W.2d 124 (Tex. 1939) (defendant may obtain new trial if failure to appear was not intentional, there is a meritorious defense, and no delay/injury results)
Wilson v. Dunn, 800 S.W.2d 833 (Tex. 1990) (default judgment cannot stand if service did not strictly comply with rules; no presumption of proper service)
Primate Constr., Inc. v. Silver, 884 S.W.2d 151 (Tex. 1994) (party seeking to uphold default judgment bears burden to prove proper service)
Reed Elsevier, Inc. v. Carrollton-Farmers Branch Indep. Sch. Dist., 180 S.W.3d 903 (Tex. App.—Dallas 2005) (return of service must show the addressee’s capacity to establish service on corporation)