Woodworth v. Smith

BLUE, Acting Chief Judge.

In this interlocutory appeal, Timothy Woodworth appeals the denial of his motion to quash service of process. He argues that the trial court erred in finding compliance with the requirements for substituted service in chapter 48, Florida Statutes (1997). We agree and reverse.

The trial court found that Mr. Woodworth had actual notice based on regular mail. The statutory requirements for substituted service of process are strictly construed. See George Fischer, Ltd. v. Plastiline, Inc., 379 So.2d 697 (Fla. 2d DCA 1980). Pertinent to this case, the statute requires that…