Lake Oswego Review, Inc. v. Steinkamp

This case presents an issue of first impression under the Oregon Rules of Civil Procedure. The issue is whether service of summons on an individual by certified mail, return receipt requested (restricted delivery), is valid service pursuant to ORCP 7. We hold that, under the facts of this case, it is.

Plaintiff mailed the summons and complaint to defendant at a particular address, certified, return receipt requested (restricted delivery). The letter carrier, who knew defendant, delivered the letter to defendant at a different address and had him sign for it. Plaintiffs proof of service…