L.F. Noll Inc. v. Dope Eviglo, 816 N.W.2d 391

L.F. Noll sued Dope Eviglo in Iowa for damages related to terminating a Sioux City lease; service attempted by certified mail to a forwarding address Eviglo provided was returned as not known/unforwardable; a default judgment was entered against Eviglo.
L.F. Noll garnished Eviglo’s Nebraska wages based on the Iowa default judgment; Eviglo moved to quash garnishment.
Eviglo challenged the garnishment on (1) failure to comply with Iowa Code § 617.3 and (2) facial/as-applied constitutional grounds.
The district court upheld service under § 617.3 and rejected due process/equal protection challenges; Eviglo appealed.
The Iowa Supreme Court reversed, holding the default judgment void for lack of personal jurisdiction under § 617.3 and remanding to grant the motion to quash garnishment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is service under Iowa Code § 617.3 valid where the certified mail to the forwarding address was returned as not known/unforwardable?	Noll argues forwarding address satisfies § 617.3	Eviglo argues forwarding address is not an actual address where service can be effected	No; service invalid; address must be one where defendant can be found.
What is the meaning of “an address in the state of residence” under § 617.3?	Noll treats any reasonably connected address as valid for notice	Eviglo contends only a valid, current address suffices	“An address” means a place where the person can be found for service.
Does due process require additional steps beyond mailing when delivery cannot be completed?	Noll relies on statutory interpretation and avoids constitutional issues	Eviglo cites Jones v. Flowers and argues due process requires further notice steps	The court avoids constitutional ruling but notes Jones-inspired safeguards; service must be adequate under statute.
Should the underlying default judgment be void for lack of personal jurisdiction given improper service?	Noll contends service defects void the judgment	Eviglo maintains service complied with the statute	Yes; the default judgment is void; garnishment must be quashed and remanded.

Barrett v. Bryant, 290 N.W.2d 917 (Iowa 1980) (service to wrong address can render notice invalid; some recipients may still be effectively served if address is close enough)
Emery Transportation Co. v. Baker, 254 Iowa 744 (Iowa 1963) (required actual or offered delivery under restricted mail; distinction between unclaimed and refused)
Buena Vista Manor v. Century Mfg. Co., 221 N.W.2d 286 (Iowa 1974) (ten-day receipt period measured from mailing; notice should be effectively delivered)
Escher v. Morrison, 278 N.W.2d 9 (Iowa 1979) (service by restricted mail; unclaimed may render service ineffective; farm tenancy context)
Jones v. Flowers, 547 U.S. 220 (2006) (due process requires additional steps beyond mailing to achieve notice when mail is returned)
War Eagle Village Apartments v. Plummer, 775 N.W.2d 714 (Iowa 2009) (due process considerations in private-party notices; doctrine of constitutional avoidance favored)