HALL v. NORTON - Service by publication invalid

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Court of Appeals of Washington State

Service by publication requires reasonably diligent efforts to locate the defendant by exhausting all information readily available. Randy Hall's mail to Tracey Norton and Darren Kossen at their last known address was returned stamped with "no forwarding address." Hall's attorney "conducted research on the internet." A prior attempt to serve Norton and Kossen at the last known address was unsuccessful when a woman in the house refused to come to the door. No other details were offered in support of service by publication. Hall knew the name of Kossen's employer and Kossen's prior address, but did not describe any efforts to pursue those leads. Hall's reliance upon "research on the internet" is vague and general. Because Hall did not support the service by publication with a showing of reasonable diligence, the default judgment taken based upon that service is void. We reverse.

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HALL v. NORTON - Service by publication invalid