Goettemoeller v. Twist

¶1 — Service of a summons at a private mailbox is not sufficient to effectuate substitute service under RCW 4.28.080(16) when that mailbox is not the defendant’s usual mailing address. Here, the defendant had moved to England more than two years earlier and there was no evidence that the private mailbox address at which service was attempted was the defendant’s “usual mailing address,” and thus there was no valid substitute service. Accordingly, we reverse the trial court and remand for dismissal for improper service.

FACTS

¶2 Graham and Susan Twist (together Twist) moved to Washington State…