Pruitt v. Palm

In April 1993 Sally Davis Palm filed a personal injury action against Lawson Pruitt, alleging that she had sustained injuries due to Pruitt's negligent and/or wanton operation of his motor vehicle.

Palm attempted service on Pruitt by certified mail. The certified mail receipt was returned unsigned. An alias summons and complaint was subsequently issued by certified mail to the same address. The receipt was signed by Pruitt's sister. Service was allegedly perfected on June 9, 1993.

In September 1993 Palm requested that the trial court grant a default judgment in her favor. In December 1993 a…