MYRMAC Corporation A/K/A McDonalds v. P.H., Individually and as Next Friend of C.H., 02-16-00319-CV

On Jan 21, 2015 P.H. (Mother), individually and as next friend of C.H., sued MYRMAC Corp. a/k/a McDonalds for negligence arising from a playground injury.
Mother alleged service could be made on McDonalds’s registered agent, Judith Savage, at a Weatherford, Texas address; the citation named Savage as agent and included Mother’s petition.
Clerk’s return of service stated the documents were sent by certified mail to "MYRMAC Corporation" at a Chicago address, and the attached return receipt showed delivery at the Weatherford address and was signed by Irma Medina (no indication of her authority).
McDonalds did not answer or appear; the trial court held a default hearing, awarded $55,000, and mailed notice of the default judgment to the Weatherford address.
McDonalds filed a restricted appeal arguing service was defective; the Court of Appeals considered whether the record showed jurisdictionally sufficient service of process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service by certified mail complied with Tex. R. Civ. P. 107 when the return receipt was signed by a person (Irma Medina) whose authority was not shown	Service was effective because the return receipt shows delivery to the agent at the Weatherford address	Service was defective because the return receipt lacked the addressee or an identified authorized agent’s signature, so authority of the signer is unknown	Held: Return was defective; signer’s authority not shown, so service failed and court lacked personal jurisdiction; default judgment reversed
Whether the address discrepancy between the citation (Weatherford) and the return (Chicago) invalidated service	Citation and petition correctly named Weatherford agent; any discrepancy is harmless	Address mismatch renders the return inconsistent with citation and defective	Court did not address this issue on the merits (declined to reach second issue)

Primate Constr., Inc. v. Silver, 884 S.W.2d 151 (Tex. 1994) (strict compliance with service rules required for default judgment)
Wilson v. Dunn, 800 S.W.2d 833 (Tex. 1990) (jurisdictional requirements for service must be met)
Watson v. Watson, 286 S.W.3d 519 (Tex. App.—Fort Worth 2009) (restricted-appeal standards)
Arnell v. Arnell, 281 S.W.3d 549 (Tex. App.—El Paso 2008) (restricted-appeal standards)
Etheredge v. Hidden Valley Airpark Ass’n, Inc., 169 S.W.3d 378 (Tex. App.—Fort Worth 2005) (restricted-appeal considerations)
Reed Elsevier, Inc. v. Carrollton-Farmers Branch ISD, 180 S.W.3d 903 (Tex. App.—Dallas 2005) (record must show whether recipient authorized to accept service)
Master Capital Solutions Corp. v. Araujo, 456 S.W.3d 636 (Tex. App.—El Paso 2015) (service by mail defective when recipient’s authority not shown)
Uvalde Country Club v. Martin Linen Supply Co., 690 S.W.2d 884 (Tex. 1985) (defective service voids default judgment)