Dec v. Manning

In this consolidated appeal, we are presented with questions concerning the propriety of a default judgment predicated upon substituted service of process.

The procedural history of this case is both complex and confusing. On September 6, 1983, plaintiff Michael Coan filed his original complaint against defendant, George Manning, in which Coan alleged that Manning owed him $1,500 “earnest money never received” and $5,000 for “architect’s fees.” Following the return of two unserved summons, the circuit court appointed a special process server. On December 13, 1983, the summons was returned,…