Background - Thompson sued Braggs for assault/battery and attempted service multiple times at different addresses after an initial summons went unserved. - A sheriff made three unsuccessful attempts at 14528 Des Plaines St.; a special process server later claimed to serve Braggs at 15722 Spaulding Ave. but Braggs denied ever living or being served there. - The circuit court granted a motion to quash that service, allowed an alias summons listing 151 S. Desplaines St. (Joliet), and appointed a special process server. - After further unsuccessful attempts, Thompson moved for alternative service under 735 ILCS 5/2-203.1, supported by a skip trace (dated Feb 2015) and affidavits recounting two attempts at the Spaulding address in Jan 2016. - The circuit court authorized alternative service by certified mail and posting; Thompson mailed and later posted (disputed) the summons. Braggs moved to dismiss for lack of personal jurisdiction, arguing Thompson failed to show diligence in locating her at the 151 S. Desplaines address she had previously provided. - The trial court denied Braggs’s motion; on interlocutory appeal the appellate court reversed, finding Thompson failed to satisfy section 2-203.1’s diligent inquiry requirement and quashed the mailing/posting service. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---:| | Whether plaintiff satisfied the diligence requirement of 735 ILCS 5/2-203.1 to obtain court-ordered alternative service | Thompson argued he incurred significant expense, performed a skip trace, and made service attempts that justified alternative service | Braggs argued Thompson failed to conduct a diligent inquiry after she supplied her Joliet address and made no reasonable effort to serve her there | Court held Thompson failed to demonstrate a diligent inquiry or reasonable efforts at the 151 S. Desplaines address; section 2-203.1 not satisfied | | Whether mailing and posting under the court’s alternative-service order conferred personal jurisdiction | Thompson relied on the court’s order authorizing certified mail and posting to argue service was valid | Braggs argued the court lacked authority to order alternative service because statutory prerequisites were unmet, so mailing/posting did not confer jurisdiction | Court held the alternative-service order was invalid for lack of statutory compliance; mailing/posting did not effect valid service | ### Key Cases Cited BAC Home Loans Servicing, LP v. Mitchell, 2014 IL 116311 (discussing standard of review and personal jurisdiction through service) Mugavero v. Kenzler, 317 Ill. App. 3d 162 (plaintiff must strictly comply with section 2-203.1 affidavit and diligence requirements) In re Dar. C., 2011 IL 111083 (explaining diligence requirements for locating absent parties) People v. Wallace, 405 Ill. App. 3d 984 (service requirements ensure due notice; remediable technical service errors) State Bank of Lake Zurich v. Thill, 113 Ill. 2d 294 (court acquires personal jurisdiction by appearance or statutory service) White v. Ratcliffe, 285 Ill. App. 3d 758 (standards for reviewing personal jurisdiction questions)