Lance Koster v. Carol Sullivan

This case is before the Court for review of the decision of the Second District Court of Appeal in Koster v. Sullivan, 103 So.3d 882 (Fla. 2d DCA 2012). In its decision, the district court ruled upon the following question, which the court certified to be of great public importance:

IS A RETURN OF SERVICE, IN ORDER TO BE DEEMED REGULAR ON ITS FACE SUCH THAT THE PARTY SEEKING TO ESTABLISH SERVICE IS ENTITLED TO A PRESUMPTION OF VALID SERVICE, REQUIRED TO EXPRESSLY LIST THE FACTORS DEFINING THE “MANNER OF SERVICE” INDICATED ON THE RETURN THAT ARE OTHERWISE IDENTIFIED IN STATUTES DEFINING SERVICE…