Wayne County Department of Social Services v. Orbaker

A summons and petition to appear in this support proceeding was mailed to the respondent pursuant to subdivision (c) of section 427 of the Family Court Act. This section, since April 22, 1975, has provided for service of a summons by mail "in any case”, whether or not service is attempted personally under subdivision (a) or by substituted service under subdivision (b). Protection is given a respondent by prevention of a default without satisfactory proof that the respondent had actual notice of the commencement of the proceeding.

On the return day, respondent appeared specially in person and…