JURISDICTION

Although we review a district court's Rule 60(b)(4) motion for abuse of discretion, insufficient service of process under Rule 60(b)(4) implicates personal jurisdiction and due process concerns. Generally, where service of process is insufficient, the court has no power to render judgment and the judgment is void. See Varnes v. Local 91, Glass Bottle Blowers Ass'n, 674 F.2d 1365, 1368 (11th Cir. 1982) (finding a judgment void under Rule 60(b)(4) where the defendant was not properly served); see also Mullane v. Cent. Hanover Bank Trust Co., 339 U.S. 306, 314, 70 S.Ct. 652, 657, 94 L.Ed. 865 (1950) ("An elementary and fundamental requirement of due process in any proceeding ... accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the... action and [to] afford them an opportunity to present their objections." (citations omitted)).

Courts have an independent obligation to satisfy themselves of their own jurisdiction

Jurisdiction is a threshold inquiry that must be resolved before addressing the merits.

A party is bound by the admission in its pleadings for jurisdictional determinations.

Because jurisdiction is conferred upon courts by constitution or by statute, jurisdictional requirements established by statute must be strictly construed.

substantial proceedings in an improper forum cannot cure jurisdictional defects.

Jurisdiction is the power to act. Its absence renders a judgment void.

Delaying resolution of jurisdictional issues until after trial results in greater inefficiency, not less.