National Development Co. v. Triad Holding Corp.

MCLAUGHLIN, Circuit Judge:

For more than a half-century, the Federal Rules of Civil Procedure have permitted service upon an individual by leaving a summons and complaint “at the individual’s dwelling house or usual place of abode.” For a half-century before that, Equity Rule 13 had the same provision. With approximately 1.16 billion passengers annually engaging in international airline travel, see Washington Times, Jan. 1, 1991, at Cl col. 1, and an estimated five million people with second homes in the United States, see Stern, Steal This House, Forbes, Oct. 1, 1990, at 81, determining a…