In Sheldon v. Fettig, the Washington Supreme Court announced a new rule for interpreting Washington's substitute service of process statute. This new rule calls for a liberal reading of the substitute service of process statute to better effect its legislative purpose, thus overruling the line of cases calling for strict construction of the substitute service of process statute. This Note analyzes the basis of the former rule, the Sheldon rule, and the Sheldon dissent's proposed rule. It concludes that the former rule of interpretation should be retained because it preserves canons of strict construction and better protects defendants' due process rights.
Notes and Comments,
Sheldon v. Fettig: Interpreting the Substitute Service of Process Statute in Washington,
72 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol72/iss2/11