Background - Thompson sued Ross Dialysis, Fresenius, and employee Jamila(la) Braggs for assault/battery; summonses issued against Braggs starting Feb 2015. - Multiple initial service attempts failed at addresses tied to Braggs (14528 Des Plaines; 15722 Spaulding). A May 2015 process-server affidavit claimed service at Spaulding; Braggs swore she never lived there since 2012 and denied being served. - Court quashed the May 2015 service, granted leave for alias summonses, and an alias with address 151 S. Desplaines (Joliet) was issued Sept 2015. - After further unsuccessful attempts, Thompson moved (Feb–Mar 2016) for alternative service under 735 ILCS 5/2-203.1, supported by a 2015 skip trace and a January 2016 nonservice affidavit describing refusals at the Spaulding address. - The circuit court granted alternative service by certified mail and posting; Thompson mailed and claimed posting. Braggs moved to dismiss for lack of personal jurisdiction, asserting Thompson failed to demonstrate the required diligent inquiry and reasonable efforts to effectuate personal or substitute service at her asserted address (151 S. Desplaines). - The appellate court allowed interlocutory review, reversed the grant of alternative service, quashed the mail/posting service, and remanded. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---:| | Whether plaintiff satisfied section 2-203.1 diligence requirement to obtain court-ordered alternative service | Thompson argued he incurred significant expense, attached a skip trace, and submitted a process-server affidavit showing attempts at locations linked to Braggs | Braggs argued Thompson failed to show a diligent inquiry or reasonable efforts to serve her at her known address (151 S. Desplaines) and thus was not entitled to alternative service | Court held Thompson did not meet the statutory diligence requirement; alternative service improperly granted and service by mail/posting quashed | ### Key Cases Cited Mugavero v. Kenzler, 317 Ill. App. 3d 162 (Ill. App. Ct.) (plaintiff seeking alternative service must strictly comply with statutory affidavit requirement) State Bank of Lake Zurich v. Thill, 113 Ill. 2d 294 (Ill. 1986) (personal jurisdiction obtained only by appearance or statutorily directed service) * People v. Wallace, 405 Ill. App. 3d 984 (Ill. App. Ct.) (service requirements protect due notice; where party has notice but service defective, remedy may be proper re-service)