Registered Agent is not a "statutory agent" according to S.C. Supreme Court

In Harbor Island Owners' Association v. Preferred Island Properties, Inc., the South Carolina Supreme Court considered, among other things, whether a registered agent is a statutory agent under the South Carolina Rules of Civil Procedure. Rule 6(e) provides:

Whenever a party has the right or is required to do some act or take some proceedings within a prescribed period after the service of a notice or other paper upon him and the notice or paper is served upon him by mail or upon a person designated by statute to accept service, five days shall be added to the prescribed period

This was significant because Preferred Island argued that a default judgment entered against it was a nullity because the affidavit of default was filed 34 days after service on its registered agent, making it invalid because Preferred Island still had one more day to answer under Rule 6(e).

The Supreme Court disagreed, holding that a "registered agent" is not a "person designated by statute to accept service" and that Rule 6(e) therefore did not apply.