eyer, 311 U.S. 457, 462-464 (1940).
[699] McDonald _v._ Mabee, 243 U.S. 90, 92 (1917).
[700] Thus, in an older decision rendered in 1919, the Court held that
whereas "States could exclude foreign corporations * * *, and therefore
establish * * * [appointment of such an agent] as a condition to letting
them in," they had no power to exclude individuals; and as a
consequence, a statute was ineffective which treated nonresident
partners, by virtue of their having done business therein, as having
consented to be bound by service of process on a person who was their
employee when the transaction sued on arose but was not their agent at
the time of service.--Flexner _v._ Farson, 248. U.S. 289, 293 (1919).
Because it might be construed to negative extension to nonresidents,
other than motorists, of the statutory device upheld in Hess _v._
Pawloski, the doctrine of Flexner _v._ Farson, "that the mere
transaction of business in a State by a nonresident natural person does
not imply consent to be bound by the process of its courts," was
recently condemned as inadequate "to cope with the increasing problem of
practical responsibility of hazardous business conducted in absentia * *
*"--Sugg _v._ Hendrix, 142 F. (2d) 740, 742 (1944).
[701] Hess _v._ Pawloski, 274 U.S. 352 (1927); Wuchter _v._ Pizzutti,
276 U.S. 13, 20, 24 (1928).
[702] 326 U.S. 310, 316 (1945).
[703] 326 U.S. 310.
[704] Philadelphia & Reading Ry. Co. _v._ McKibbin, 243 U.S. 264, 265
(1917).
[705] In a very few cases, "continuous operations within a State were
thought to be so substantial and of such a nature as to justify suits
against [a foreign corporation] on causes of action arising from
dealings entirely distinct from those" operations.--_See_ St. Louis
S.W.R. Co. _v._ Alexander, 227 U.S. 218 (1913); Missouri, K. & T.R. Co.
_v._ Reynolds, 255 U.S. 565 (1921).
[706] Old Wayne Life Assn. _v._ McDonough, 204 U.S. 8, 21 (1907).
[707] Simon _v._ Southern R. Co., 236 U.S. 115, 129-130 (1915).--In
neither this case, nor the preceding decision were the defendant
corporations notified of the pendency of the action, service having been
made only on the Insurance Commissioner or the Secretary of State.
[708] Green _v._ Chicago, B. & Q.R. Co., 205 U.S. 530 (1907). _See also_
Davis _v._ Farmers Co-operative Co., 262 U.S. 312, 317 (1923).
[709] Pennsylvania F. Ins. Co. _v._ Gold Issue Min. & M. Co., 243 U.S.
93, 95-96 (1917).
[710] Rosenberg Bros
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