s only procedures
d to give
notice. Id. (sub
tutes have been
inst attack on du
citing Milliken v.
U.S. 457 (1940))
ce with s
uch statutes is
od of acquiring j
n over de
fendant even if
did not receive a
g, 109 F.R.D. at
y be delivered to
cess does not
So. 2d at
years prior to incarceration, who were still married at the time
15, § 48.0
that the papers
those who, like Shurman, lived in their family home for many
In the end, Shurman's incarceration does not violate due
of service and whose family still lived in that same home.
Since Shurman clearly never intended to establish a place of
abode anywhere other than where he had lived previously and where
his family continued to live after he was incarcerated, that home
remained his "place of abode" even though he was temporarily
Although personal service on Shurman in prison may have been an
alternative, it Statutes (1998)
was not required.
See, § 48.051, Florida
District noted, § 48.051 simply provides that prisoners are to
served in the same manner as other natural persons.
A.1. Other natural substitute service.
persons can be served in person or § 48.031, Florida Statues (1998).