The case of the day is Larson v. Yoon (Wash. Ct. App. 2015). Keith and Cynthia Larson sued Kyungsik Yoon after an auto collision in King County, Washington. The Larsons lived there; Yoon was a resident of South Korea. The Larsons sued and sought to serve Yoon with process by service on the Washington secretary of state, as provided by Washington statutes. The secretary of state then mailed the documents to Yoon, again as provided by statute. Yoon sought summary judgment on the grounds that he had not been properly been served. The court denied the motion, and Yoon took an interlocutory appeal.

The court held, correctly, that the statute is inconsistent with the the Hague Service Convention for service in Korea, because Korea has objected to service by postal channels. Thus, as the court noted, the Supremacy Clause preempted the Washington statute.