In re the Marriage of Mu Chai
Court of Appeals of Washington
1Opinion of the Court
Ellington, A.C.J.
A decree of legal separation may be converted to a decree of dissolution by motion of either party. We hold that due process does not require new original process for such a motion. The rule permits service *250by personal delivery or by mail to a last known address. But Mu Chai simply left a copy of his motion in a mailbox. This method of “service” did not comply with the rules, substantially or otherwise. Where the court has personal and subject matter jurisdiction, procedural irregularities render a judgment voidable, not void. Mu Chai’s decree of dissolution was thus…
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