Matthew M. Spanton and Elisha Spanton D/B/A Hill Country Kennels v. Pamela S. Bellah, 612 S.W.3d 314

Pamela Bellah sued Matthew and Elisha Spanton for negligence, alleging a dog at their Hill Country Kennels attacked her; petition and citation listed the Spantons’ residence at a specific house number on “Heather Hills Dr.” in Dripping Springs.
After failed personal service attempts, Bellah obtained a court order authorizing substitute service; some filings and the order used the street name spelled “Heather s Hill” while others (citation, return, default motion) used “Heather Hill s” (inconsistent street name).
The process server filed an affidavit and a return stating substitute service was effected by posting to the gate and by certified mail to the listed Heather Hill(s) address; certified mail was returned “UNCLAIMED,” and first-class mail was returned with a Spicewood forwarding address.
The trial court entered a default judgment awarding Bellah $950,000 and mailed abstracts to the Heather Hill(s) address.
The Spantons filed a restricted appeal alleging improper service; the court of appeals upheld the judgment, but the Texas Supreme Court granted review and vacated the default judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substitute service complied with the trial court’s order when the return used a different street-name spelling/address	Discrepancy is minor; return and affidavits show effective substituted service and notice	Strict compliance required with the trial court’s substitute-service order; differing street names may indicate service at a different place	The Court held substitute service did not strictly comply with the order because the return used a different street name; discrepancy was fatal and the default judgment was vacated
Whether the face of the record supported the default judgment on restricted appeal (i.e., whether service can be presumed valid)	The affidavit, return, posting, and mailings show reasonably effective notice and sufficiency on the face of the record	Certified mail was unclaimed, first-class was forwarded; the record does not show actual receipt and contains the address discrepancy	The Court held no presumption may be indulged; the face of the record showed noncompliance, so restricted-appeal relief was warranted

Wilson v. Dunn, 800 S.W.2d 833 (Tex. 1990) (no-answer default judgments require strict compliance with service rules)
Holt Atherton Indus., Inc. v. Heine, 835 S.W.2d 80 (Tex. 1992) (default judgments are disfavored)
Uvalde Country Club v. Martin Linen Supply Co., 690 S.W.2d 884 (Tex. 1985) (service not strictly complying with rules is invalid)
McKanna v. Edgar, 388 S.W.2d 927 (Tex. 1965) (indulge no presumptions as to service)
Primate Constr., Inc. v. Silver, 884 S.W.2d 151 (Tex. 1994) (strict compliance standard reiterated)
Ex parte E.H., 602 S.W.3d 486 (Tex. 2020) (on restricted-appeal jurisdiction and face-of-record review)
Broussard v. Davila, 352 S.W.2d 753 (Tex. Civ. App.—San Antonio 1961) (substitute service authorized only on terms stated in the court’s order)