Third Fed. S. & L. Assn. v. Taylor, 2017 Ohio 7620

Third Federal filed a foreclosure complaint (Sept. 15, 2015) against James R. Taylor III, Sylvia Taylor, and Demetrius D. Faulkner for property at 2704 Woodcutter Ave.; an amended complaint later added Roy Faulkner.
Service by certified mail failed because Third Federal did not supply or had incorrect addresses; attempted certified-mail service to addresses provided for the Faulkners was returned as undeliverable.
Third Federal's counsel filed an affidavit averring he did not know the defendants’ residences and described efforts to locate them: a search of Franklin County probate records and hiring OPENonline (which uses LexisNexis Accurint).
Notice by publication ran in the Daily Reporter Nov. 30, Dec. 7, and Dec. 14, 2015; none of the three defendants timely responded, and the court entered default judgment and foreclosure on Jan. 29, 2016.
Defendants moved to vacate the judgment (Sept. 21, 2016), arguing service by publication was invalid because Third Federal failed to exercise "reasonable diligence" under Civ.R. 4.4(A); the trial court denied the motion and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service by publication was proper under Civ.R. 4.4(A)	Third Federal exercised reasonable diligence by searching probate records and using OPENonline/Accurint to locate addresses	Third Federal failed to perform sufficiently diligent searches (e.g., internet queries like Google, ask neighbors, serve at property address)	Court held Third Federal acted with reasonable diligence; service by publication was valid and conferred personal jurisdiction

Maryhew v. Yova, 11 Ohio St.3d 154 (establishes requirement of personal jurisdiction for valid judgment)
Patton v. Diemer, 35 Ohio St.3d 68 (Ohio courts may vacate void judgments)
Sizemore v. Smith, 6 Ohio St.3d 330 (reasonable-diligence standard for service by publication)
In re Thompkins, 115 Ohio St.3d 409 (clarifies and applies Sizemore reasonable-diligence factors)