invalid if served after a notice of removal to federal court is filed. 381 F.2d at 373. While this interpretation is the rule in the Ninth Circuit, it is not necessarily the rule in Arizona state courts. See Ritchie v. Grand, Canyon Scenic Rides, 165 Ariz. 460, 464, 799 P.2d 801, 805 (1990) (Arizona courts are not bound by federal court decisions if “Arizona policy, practice, or case law requires a different result.”). ¶ 10 Moreover, the Ninth Circuit interpretation is not unanimous among the federal courts. Some courts have flatly rejected it. See, e.g., Listle v. Milwaukee County, 926 F.Supp. 826, 827 (E.D.Wis.1996), aff'd, 138 F.3d 1155 (7th Cir.1998) (citing Continental Ill. National Bank and Trust Co. of Chicago v. Protos Shipping, Inc., 472 F.Supp. 979, 982-83 (N.D.Ill.1979) (<HOLDING>)). The federal courts in Wisconsin and Illinois
holding that a defendants actual knowledge that an action is pending or that service has been attempted is not the equivalent of service of summons and will not relieve the plaintiff of its burden or vest the court with jurisdiction recognizing that it is well settled law that an action is commenced by the service of a summons and without valid service of process the trial court has no jurisdiction to act holding that service is not avoided by service on a partys attorney as service on an attorney is ineffective unless he has been authorized to accept such service holding that service of a statecourt summons and complaint after removal to federal court is valid service holding that if service done by certified mail action commenced upon receipt of summons and complaint