Florida Statutes

Fla. Stat. § 48.031 (2025)

Service of process generally; service of witness subpoenas.

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48.031 Service of process generally; service of witness subpoenas.—

(1)(a) Service of original process is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading or paper or by leaving the copies at his or her usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents. Minors who are or have been married shall be served as provided in this section.

(b) An employer, when contacted by an individual authorized to serve process, shall allow the authorized individual to serve an employee in a private area designated by the employer. An employer who fails to comply with this paragraph commits a noncriminal violation, punishable by a fine of up to $1,000.

(2)(a) Substituted service on the spouse of the person to be served may be made at any place in a county by an individual authorized under s. 48.021 or s. 48.27 to serve process in that county, if the cause of action is not an adversarial proceeding between the spouse and the person to be served, if the spouse requests such service or the spouse is also a party to the action, and if the spouse and person to be served reside together in the same dwelling, regardless of whether such dwelling is located in the county where substituted service is made.

(b) Substituted service may be made on an individual doing business as a sole proprietorship at his or her place of business, during regular business hours, by serving the person in charge of the business at the time of service if two attempts to serve the owner are made at the place of business.

(3)(a) The service of process of witness subpoenas, whether in criminal cases or civil actions, shall be made as provided in subsection (1). However, service of a subpoena on a witness in a civil traffic case, a criminal traffic case, a misdemeanor case, or a second degree or third degree felony may be made by United States mail directed to the witness at the last known address, and the service must be mailed at least 7 days prior to the date of the witness’s required appearance. Failure of a witness to appear in response to a subpoena served by United States mail that is not certified may not be grounds for finding the witness in contempt of court.

(b) A criminal witness subpoena commanding the witness to appear for a court appearance may be posted by a person authorized to serve process at the witness’s residence if three attempts to serve the subpoena, made at different times of the day or night on different dates, have failed. A criminal witness subpoena commanding the witness to appear for a deposition may be posted by a person authorized to serve process at the witness’s residence if one attempt to serve the subpoena has failed. The subpoena must be posted at least 5 days before the date of the witness’s required appearance.

(4)(a) Service of a criminal witness subpoena upon a law enforcement officer or upon any federal, state, or municipal employee called to testify in an official capacity in a criminal case may be made as provided in subsection (1) or by delivery to a designated supervisory or administrative employee at the witness’s place of employment if the agency head or highest ranking official at the witness’s place of employment has designated such employee to accept such service. However, no such designated employee is required to accept service:

1. For a witness who is no longer employed by the agency at that place of employment;

2. If the witness is not scheduled to work prior to the date the witness is required to appear; or

3. If the appearance date is less than 5 days from the date of service.

The agency head or highest ranking official at the witness’s place of employment may determine the days of the week and the hours that service may be made at the witness’s place of employment.

(b) Service may also be made in accordance with subsection (3) provided that the person who requests the issuance of the criminal witness subpoena shall be responsible for mailing the subpoena in accordance with that subsection and for making the proper return of service to the court.

(5) A person serving process shall place, on the first page only of at least one of the processes served, the date and time of service, his or her initials or signature, and, if applicable, his or her identification number. The person requesting service or the person authorized to serve the process shall file the return-of-service form with the court.

(6)(a) If the only address for a person to be served which is discoverable through public records is a private mailbox, a virtual office, or an executive office or mini suite, substituted service may be made by leaving a copy of the process with the person in charge of the private mailbox, virtual office, or executive office or mini suite, but only if the process server determines that the person to be served maintains a mailbox, a virtual office, or an executive office or mini suite at that location.

(b) For purposes of this subsection, the term “virtual office” means an office that provides communications services, such as telephone or facsimile services, and address services without providing dedicated office space, and where all communications are routed through a common receptionist. The term “executive office or mini suite” means an office that provides communications services, such as telephone and facsimile services, a dedicated office space, and other supportive services, and where all communications are routed through a common receptionist.

(7) A gated residential community, including a condominium association or a cooperative, shall grant unannounced entry into the community, including its common areas and common elements, to a person who is attempting to serve process on a defendant or witness who resides within or is known to be within the community.

History.—s. 5, Nov. 23, 1828; RS 1015; GS 1402; RGS 2599; CGL 4246; s. 6, ch. 29737, 1955; s. 4, ch. 67-254; s. 1, ch. 75-34; s. 3, ch. 79-396; s. 3, ch. 82-118; s. 1, ch. 84-339; s. 7, ch. 85-80; s. 2, ch. 87-405; s. 6, ch. 93-208; s. 269, ch. 95-147; s. 1, ch. 95-172; s. 1, ch. 98-410; s. 1, ch. 2004-273; s. 2, ch. 2011-159; s. 2, ch. 2014-207; s. 1, ch. 2015-51; s. 1, ch. 2015-59; s. 1, ch. 2016-207; s. 4, ch. 2019-67.

Note.—Former s. 47.13.

Notes of Decisions

Cited in 269 cases (88 in the last 5 years), 1969–2026 · leading case: Lance Koster v. Carol Sullivan, 160 So. 3d 385 (Fla. 2015).

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Lance Koster v. Carol Sullivan, 160 So. 3d 385 (Fla. 2015). · cites it 22× “The pertinent portion of section 48.031 provided: 48.031 Service of process generally; service of witness subpoenas.”

Shurman v. Atl. Mortg. & Inv. Corp., 795 So. 2d 952 (Fla. 2001). · cites it 14× “Following an evidentiary hearing on Shurman's motion, the trial court concluded that Shurman's "usual place of abode" for purposes of serving process under section 48.031, Florida Statutes (1997), was the residence where he lived with his wife prior to his incarceration and…”

Robles-Martinez v. Diaz, Reus & Targ, LLP, 88 So. 3d 177 (Fla. 3d DCA 2011). · cites it 14× “Service made under the substitute service provisions of section 48.031, Florida Statutes, must be strictly complied with, and these provisions are to be strictly construed.”

John Coffin v. Stacy Brandau, 642 F.3d 999 (11th Cir. 2011). · cites it 6× “Compare Fla. Stat. Ann. § 48.031 (West 2011) with N.”

Rodriguez v. State, 919 So. 2d 1252 (Fla. 2006). · cites it 4× “The judge explained that Rodriguez had served the subpoenas on these witnesses only one day before the hearing and the witnesses rightly claimed that their attendance was an undue burden and a violation of section 48.031(4), Florida Statutes (1995), which governs service of…”

Beckley v. Best Restorations, Inc., 13 So. 3d 125 (Fla. 4th DCA 2009). · cites it 14× “We reverse the trial court’s order denying the Defendants’ cross-motion to quash service of process because section 48.031(6), Florida Statutes (2008) was not a valid method for the Plaintiff to serve the Defendants.”

Anthony v. Gary J. Rotella & Assocs., 906 So. 2d 1205 (Fla. 4th DCA 2005). · cites it 5× “2d DCA 1993) (affirming the lower court's order quashing service of process because "service on the business manager does not satisfy the requirements for obtaining personal service on an individual pursuant to section 48.031, Florida Statutes (1991)").”

Koster v. Sullivan, 103 So. 3d 882 (Fla. 2d DCA 2012). · cites it 10× “The Third District has suggested that “[s]ervice made under the substitute service provisions of section 48.031 ... must be strictly complied with and [that] these provisions are to be strictly construed.”

Coutts v. Sabadell United Bank, N.A., 199 So. 3d 1099 (Fla. 3d DCA 2016). · cites it 10× “2015), wherein the court addressed whether “the specifics regarding the manner of service as set forth in section 48.031 must be indicated in a valid return of service.”

Vidal v. SunTrust Bank, 41 So. 3d 401 (Fla. 4th DCA 2010). · cites it 8× “” Along similar lines, service made pursuant to section 48.031(2)(b) allows substitute service on a sole proprietorship at his or her place of business during regular business hours.”

Nirk v. Bank of Am., N.A., 94 So. 3d 658 (Fla. 4th DCA 2012). · cites it 21× “” § 48.031(5), Fla. Stat. (2010) (emphasis added).”

Hauser v. Schiff, 341 So. 2d 531 (Fla. 3d DCA 1977). · cites it 8× “Based on the foregoing, the appellant moved to dismiss for lack of jurisdiction over the person, insufficiency of process, and insufficiency of service of process on the ground that process was not properly served pursuant to Section 48.031, Florida Statutes (1975). By this…”

Raul J. Cepero a/k/a Raul De Jesus Cepero & Leslie Cepero v. The Bank of New York Mellon Trust Co., 189 So. 3d 204 (Fla. 4th DCA 2016). · cites it 6× “They argued that this was not in compliance with section 48.031(2), Florida Statutes (2013).”

Clauro Enter., Inc. v. Aragon Galiano Holdings, LLC, 16 So. 3d 1009 (Fla. 3d DCA 2009). · cites it 8× “Pursuant to section 48.031(6), Florida Statutes (2008), Aragon attempted service on both Clauro and Rupcich by leaving copies of the complaint and summons with the owner of a UPS mailbox store located in Weston, Florida.”

David Davidian & Irma Davidian v. JP Morgan Chase Bank, Nat'l Ass'n, 178 So. 3d 45 (Fla. 4th DCA 2015). · cites it 6× “They were shown to comply with section 48.031 and 48.21, Florida Statutes (2015).”

Herskowitz v. Schwarz & Schiffrin, 411 So. 2d 1359 (Fla. 3d DCA 1982). · cites it 8× “His return indicated that he had served a John Doe, a person above the age of 15, who was a resident of the defendant's household, pursuant to Section 48.031, Florida Statutes (1979). The defendant moved to quash service of process, contending that both she and her son, the only…”

Conax Florida Corp. v. Astrium Ltd., 499 F. Supp. 2d 1287 (M.D. Fla. 2007). · cites it 4× “The plaintiff contends that it properly effected personal service of process upon the defendant pursuant to § 48.031, Fla. Stat., and substitute service under §§ 48.”

Mouzon v. Mouzon, 458 So. 2d 381 (Fla. 5th DCA 1984). · cites it 4× “[3] Basically there are three types of process on individuals: (1) PERSONAL SERVICE: Personal service of process under section 48.031, Florida Statutes, must be used in all actions against natural persons, if possible, and when correctly accomplished is good in all kinds of law…”

Torres v. Arnco Const., Inc., 867 So. 2d 583 (Fla. 5th DCA 2004). · cites it 4× “, was properly served with process by substitute service pursuant to section 48.031, Florida Statutes (2002). Specifically, Mr.”

In Re Amendments to Fla. Rules Civ. Proc., 604 So. 2d 1110 (Fla. 1992). · cites it 4× “Subdivision (c) is revised to conform with section 48.031, Florida Statutes (1979). RULE 1.”

McDaniel v. FirstBank Puerto Rico, 96 So. 3d 926 (Fla. 2d DCA 2012). · cites it 6× “Because the requirements of section 48.031(6), Florida Statutes (2010), were not met in effectuating substitute service against the McDan-iels, we reverse the order denying the motion to quash.”

Frank Romeo & Connie Yang v. US Bank Nat'l Ass'n, 144 So. 3d 585 (Fla. 4th DCA 2014). · cites it 8× “Section 48.031, Florida Statutes (2013), governs service of process.”

Baker v. Stearns Bank, N.A., 84 So. 3d 1122 (Fla. 2d DCA 2012). · cites it 5× “3d DCA 2011) (“Service made under the substitute service provisions of section 48.031, Florida Statutes, must be strictly complied with, and these provisions are to *1126 be strictly construed.”

Florida Dep't of Child. & Families v. Sun-Sentinel, Inc., 865 So. 2d 1278 (Fla. 2004). · cites it 2× “" Section 48.031(1)(a), Florida Statutes (2002), states that "[s]ervice of original process is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading.”

Boatfloat, LLC v. Cent. Transp. Intern., 941 So. 2d 1271 (Fla. 4th DCA 2006). · cites it 4× “Where, however, the person to be served flees from the presence of the process server in a deliberate attempt to avoid service of process, the delivery requirement of .”

Carter v. Lil'Joe Records, Inc., 829 So. 2d 953 (Fla. 4th DCA 2002). · cites it 4× “In addition to the procedure set forth in section 48.031, this state has specifically set forth the proper method for service of process on prisoners.”

Gonzalez v. Totalbank, 472 So. 2d 861 (Fla. 3d DCA 1985). · cites it 3× “In this case, service was made under section 48.031, Florida Statutes (1979) by attempting to deliver the summons and complaint to Olga Gonzalez at her "usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their…”

James Matthews & Roberta Matthews v. U.S. Bank, Nat'l Ass'n, etc., 197 So. 3d 1140 (Fla. 4th DCA 2016). · cites it 7× “” § 48.031, Fla. Stat. (2015). Appellants contend that the summonses contain illegible handwritten notations.”

Schupak v. Sutton Hill Assocs., 710 So. 2d 707 (Fla. 4th DCA 1998). · cites it 4× “Service of process on appellant was attempted pursuant to section 48.031(1), Florida Statutes (1993), which provided: "service of original process is made by delivering a copy of it to the person to be served with a copy of the complaint .”

Thompson v. State, 565 So. 2d 1311 (Fla. 1990). · cites it 2× “See § 48.031, Fla. Stat. (1987). While we might disagree with the procedure employed by the state, we do not find error here.”

Cordova v. Jolcover, 942 So. 2d 1045 (Fla. 2d DCA 2006). · cites it 4× “Cordova argues that the trial court lacked personal jurisdiction over him because he was not served with process at his usual place of abode as required by section 48.031, Florida Statutes (2004). Because Mr.”

Stoeffler v. Castagliola, 629 So. 2d 196 (Fla. 2d DCA 1993). · cites it 3× “First, service on the business manager does not satisfy the requirements for obtaining personal service on an individual pursuant to section 48.031, Florida Statutes (1991). [1] The record does not support that Castagliola waived personal service, that he tried to evade service,…”

Henzel v. Noel, 598 So. 2d 220 (Fla. 5th DCA 1992). · cites it 5× “However, Noel argues that since Henzel had deliberately attempted to avoid service of process, leaving the summons and complaint at Henzel's abode satisfied section 48.031. Noel relies, inter alia, on Haney v.”

Gilliam v. Smart, 809 So. 2d 905 (Fla. 1st DCA 2002). · cites it 2× “[3] Pursuant to section 48.031(1)(a), Florida Statutes (2001), Gilliam was served on March 14, 2001, at his usual place of abode with a person residing therein, his mother, who was over 15 years of age.”

Barnett Bank of Clearwater, NA v. Folsom, 306 So. 2d 186 (Fla. 2d DCA 1975). · cites it 8× “This case involves the question of whether substituted service of process pursuant to Fla. Stat. § 48.031 (1973) is effective where it is shown that the defendant never actually knew that the suit papers had been served.”

In Re Amend. to Fla. Rules of Civ. Proc., 682 So. 2d 105 (Fla. 1996). · cites it 2× “Subdivision (c) is revised to conform with section 48.031, Florida Statutes (1979). 1996 Amendment.”

Johnston v. HUDLETT, 32 So. 3d 700 (Fla. 4th DCA 2010). · cites it 2× “Johnston’s counsel, and Sandra Johnston was defaulted as to the material allegations of the complaint.”

In Re Amendments to Rules of Civ. Proc., 536 So. 2d 974 (Fla. 1988). · cites it 3× “The summons form for personal service on natural persons is to be used for service on natural persons under the following provisions: Florida Statutes § 48.031 (service of process generally), § 48.”

Sterling Drug, Inc. v. Wright, 342 So. 2d 503 (Fla. 1977). · cites it 2× “In Folsom the Court held that, if substitute service of process is made under Section 48.031, Florida Statutes (1973), a default judgment may not be set aside because of a showing that actual notice was not received by the defendant.”

Williams v. Nuno, 239 So. 3d 153 (Fla. 3d DCA 2018). · cites it 2× “Bryan Williams a/k/a “Birdman” (“the defendant”) appeals a non-final order denying his supplemental motion to dismiss the complaint based on insufficiency of service of process, asserting that, contrary to the return of service, the person the process server gave the summons and…”

Florida Bar, 391 So. 2d 165 (Fla. 1980). · cites it 2×

Myrick v. Walters, 666 So. 2d 249 (Fla. 2d DCA 1996). · cites it 4× “Further, a potential problem arises with the return of service in that it indicates that the summons and complaint were served on the assistant manager of Big Tim's Bar BQ, in seeming contravention of section 48.031(2)(b), Florida Statutes (1989).”

Amir A. Kammona v. Onteco Corp., 587 F. App'x 575 (11th Cir. 2014).

Ingenieria Y Exportacion De Tecnologia S.L. v. Freytech, Inc., 210 So. 3d 211 (Fla. 2d DCA 2016). · cites it 3×

Pace v. Bank of New York Mellon Trust Co., 224 So. 3d 342 (Fla. 5th DCA 2017). · cites it 2×

Roy L. Lilly v. Bank of Am., N.A., 267 So. 3d 452 (Fla. 4th DCA 2019). · cites it 4× “4th DCA 2012) (holding that section 48.031(5), Florida Statutes (2010) required the information to appear on the copy of the summons); see also Romeo v.”

Diners Club, Inc. v. Brachvogel, 395 So. 2d 1156 (Fla. 1981). · cites it 4×

Magazine v. Bedoya, 475 So. 2d 1035 (Fla. 3d DCA 1985). · cites it 3× “Magazine challenges the service arguing that: (1) his mother-in-law was not a "person residing therein" under section 48.031(1), Florida Statutes (Supp.”

Vives v. Wells Fargo Bank, N.A., 128 So. 3d 9 (Fla. 3d DCA 2012). · cites it 6×

Dusesoi v. Dusesoi, 498 So. 2d 1348 (Fla. 2d DCA 1986). · cites it 2×

Gamboa v. Jones, 455 So. 2d 613 (Fla. 3d DCA 1984). · cites it 3×

Est. of Bobinger v. Deltona Corp., 563 So. 2d 739 (Fla. 2d DCA 1990). · cites it 2×

Sadlak v. Nationstar Mortg., 252 So. 3d 302 (Fla. 3d DCA 2018). · cites it 6× “” § 48.031(a)(1), Fla. Stat. (2016). Service must be done in this manner, and the return must include the following information: Each person who effects service of process shall note on a return-of- service form attached thereto, the date and time when it comes to hand, the date…”

Cason Ex Rel. Saferight v. Hammock, 908 So. 2d 512 (Fla. 5th DCA 2005). · cites it 6×

Dep't of Revenue v. Wright, 813 So. 2d 989 (Fla. 2d DCA 2002). · cites it 4×

Thompson v. King, 523 F. Supp. 180 (M.D. Fla. 1981). · cites it 3×

Chapman v. Sheffield, 750 So. 2d 140 (Fla. 1st DCA 2000). · cites it 2×

Carone v. Millennium Settlements, Inc., 84 So. 3d 1141 (Fla. 4th DCA 2012). · cites it 3×

Panter v. Werbel-Roth Sec., Inc., 406 So. 2d 1267 (Fla. 4th DCA 1981). · cites it 2×

Cullimore v. Barnett Bank of Jacksonville, 386 So. 2d 894 (Fla. 1st DCA 1980). · cites it 2×

Fundaro v. Canadiana Corp., 409 So. 2d 1099 (Fla. 4th DCA 1982). · cites it 2×

Milanes v. Colonial Penn Ins. Co., 507 So. 2d 777 (Fla. 3d DCA 1987). · cites it 3×

Bache, Halsey, Stuart, Shields, Inc. v. Mendoza, 400 So. 2d 558 (Fla. 3d DCA 1981). · cites it 3×

Hovarth v. Aetna Life Ins. Co., 634 So. 2d 240 (Fla. 5th DCA 1994). · cites it 4×

Wakeman v. Farish, 356 So. 2d 1323 (Fla. 4th DCA 1978). · cites it 4×

Carlini v. State, Dept. of Legal Affairs, 521 So. 2d 254 (Fla. 4th DCA 1988). · cites it 2×

United States v. Shirley A. Varmado, 342 F. App'x 437 (11th Cir. 2009). · cites it 2×

Green v. Jorgensen, 56 So. 3d 794 (Fla. 1st DCA 2011). · cites it 4×

Olin Corp. v. Haney, 245 So. 2d 669 (Fla. 4th DCA 1971). · cites it 3×

Montano v. Montano, 472 So. 2d 1377 (Fla. 3d DCA 1985). · cites it 3×

Linville v. Home Sav. of Am., FSB, 629 So. 2d 295 (Fla. 4th DCA 1993). · cites it 2×

Berne v. Beznos, 819 So. 2d 235 (Fla. 3d DCA 2002).

Smith v. Cuban Am. Nat'l Found., 657 So. 2d 86 (Fla. 3d DCA 1995). · cites it 2×

Fern, Ltd. v. Road Legends, Inc., 698 So. 2d 364 (Fla. 4th DCA 1997). · cites it 2×

SH v. Dep't of Child. & Families, 837 So. 2d 1117 (Fla. 4th DCA 2003). · cites it 2×

Busman v. State, Dept. of Revenue, 905 So. 2d 956 (Fla. 3d DCA 2005). · cites it 2×

Nettles v. White, 439 So. 2d 1048 (Fla. 2d DCA 1983). · cites it 2×

Thompson v. State, Dept. of Revenue, 867 So. 2d 603 (Fla. 1st DCA 2004). · cites it 3×

Paula Johnson vs Elizabeth R. Wellborn, P.A., Morris Laing Evans Brock & Kennedy CHTD., 418 F. App'x 809 (11th Cir. 2011).

Janet Mauro & Dennis Quinn v. Wells Fargo Bank, N.A., 180 So. 3d 1083 (Fla. 4th DCA 2015). · cites it 3×

Schofield v. Wells Fargo Bank, N.A., 95 So. 3d 1051 (Fla. 5th DCA 2012). · cites it 3×

Alvarez v. State Farm Mut. Auto Ins. Co., 635 So. 2d 131 (Fla. 3d DCA 1994). · cites it 2×

Diners Club, Inc. v. Brachvogel, 370 So. 2d 443 (Fla. 3d DCA 1979). · cites it 2×

Aero Costa Rica, Inc. v. Dispatch Servs., Inc., 710 So. 2d 218 (Fla. 3d DCA 1998). · cites it 2×

Monsour v. Balk, 705 So. 2d 968 (Fla. 2d DCA 1998). · cites it 2×

TID Servs., Inc. v. Dass, 65 So. 3d 1 (Fla. 2d DCA 2010). · cites it 2× “3d DCA 2009) (outlining the conditions under which service at a private mailbox under section 48.031(6) is permitted). Here, Mr.”

Talton v. CU Members Mortg., 126 So. 3d 446 (Fla. 4th DCA 2013). · cites it 2×

Empire Beauty Salon v. Com. Loan Solutions IV, LLC, 159 So. 3d 136 (Fla. 5th DCA 2014). · cites it 2×

Brown v. U.S. Bank Nat'l Ass'n, 117 So. 3d 823 (Fla. 4th DCA 2013). · cites it 2×

Johnston v. Halliday, 516 So. 2d 84 (Fla. 3d DCA 1987). · cites it 2×

Willoughby v. Seese Realty Inc., 421 So. 2d 691 (Fla. 4th DCA 1982). · cites it 2×

Pina v. Simon-Pina, 544 So. 2d 1161 (Fla. 5th DCA 1989). · cites it 2×

Lowe v. Hart, 157 F.R.D. 550 (M.D. Fla. 1994). · cites it 2×

Younes Kabbaj v. Barack H. Obama, 568 F. App'x 875 (11th Cir. 2014).

Ubilla v. L & W Supply, 637 So. 2d 994 (Fla. 3d DCA 1994). · cites it 2×

Burtchaell v. Hoffman, 508 So. 2d 738 (Fla. 5th DCA 1987). · cites it 2×

Suntrust Bank v. Elec. Wireless Corp., 23 So. 3d 774 (Fla. 3d DCA 2009). · cites it 2×

Weiss v. Mashantucket Pequot Gaming Enter., 935 So. 2d 69 (Fla. 3d DCA 2006). · cites it 2×

Gabriela Benedetto v. U.S. Bank Nat'l Ass'n, 181 So. 3d 564 (Fla. 4th DCA 2015). · cites it 2×

Kemmerer v. Klass Assocs., Inc., 108 So. 3d 672 (Fla. 2d DCA 2013). · cites it 2×

Chancelor v. BWC Investments, 57 So. 3d 969 (Fla. 4th DCA 2011). · cites it 2×

Haney v. Olin Corp., 245 So. 2d 671 (Fla. 4th DCA 1971).

Exch. Nat'l Bank of Chicago v. Rotocast Plastics Prods., Inc., 341 So. 2d 787 (Fla. 3d DCA 1977).

Risman v. Whittaker, 326 So. 2d 213 (Fla. 4th DCA 1976). · cites it 2×

Weitzman v. Resolution Trust Corp., 608 So. 2d 510 (Fla. 4th DCA 1992). · cites it 2×

Outler v. Berman, 234 So. 2d 724 (Fla. 3d DCA 1970). · cites it 2×

Liberman v. Com. Nat. Bank of Broward Cty., 256 So. 2d 63 (Fla. 4th DCA 1971).

Sangmeister v. McElnea, 278 So. 2d 675 (Fla. 3d DCA 1973).

Weinstein v. LPI-The Shoppes, Inc., 482 So. 2d 520 (Fla. 3d DCA 1986). · cites it 2×

Rodriguez v. Nasrallah, 659 So. 2d 437 (Fla. 1st DCA 1995). · cites it 2×

Galego v. Robinson, 695 So. 2d 443 (Fla. 2d DCA 1997). · cites it 2×

Signature Flight Support LLC v. Cella (M.D. Fla. 2025). · cites it 20×

Fleischman v. Morris, 260 So. 2d 278 (Fla. 3d DCA 1972).

Barker v. Greenstreet Fin. Lp, 823 So. 2d 195 (Fla. 3d DCA 2002). · cites it 2×

Woide v. Fannie Mae, 116 So. 3d 1281 (Fla. 5th DCA 2013). · cites it 2×

Griffith v. Slade, 95 So. 3d 982 (Fla. 2d DCA 2012). · cites it 2×

Couts v. Maryland Cas. Co., 306 So. 2d 594 (Fla. 2d DCA 1975).

Cohen v. City of Miami, 54 F.R.D. 274 (S.D. Fla. 1972).

Watson v. State, 989 So. 2d 699 (Fla. 4th DCA 2008). “The process server had not been able to locate the witness at his parents' home on several occasions, but had posted service under section 48.031(3)(b), Florida Statute. Appellant then took the stand and testified that the victim had threatened him in the past and had stated…”

Jayakumar v. Osinkowska (S.D. Fla. 2023). · cites it 15×

Curtis Sherrod II, et. al. v. Briar Bay Ass'n, et. al. (S.D. Fla. 2025). · cites it 13× “The Court finds that § 48.031(1)(b) does not apply here for two reasons.”

Portfolio Recovery Assocs., LLC v. Gonzalez, 951 So. 2d 1037 (Fla. 3d DCA 2007). · cites it 2×

Campo v. Tafur, 704 So. 2d 730 (Fla. 4th DCA 1998). · cites it 2×

In Re Amendments to the Florida Rules of Crim. Procedure & Florida Rule of Appellate Procedure 9.140, 176 So. 3d 980 (Fla. 2015). · cites it 5× “Amended section 48.031(3)(b) allows a criminal witness subpoena for appearance for a deposition to be “posted by a person authorized to serve process at the witness’s residence if one attempt to serve .”

Leister v. Legal Action Bureau, Inc. (M.D. Fla. 2024). · cites it 11× “§ 48.031(6)(a). The Court accepts the process server’s statement that the address for the registered agent was residential.”

Cmty. Fed. Sav. & Loan Ass'n of the Palm Beaches v. Wright, 452 So. 2d 638 (Fla. 4th DCA 1984).

Young (S.D. Fla. 2025). · cites it 9×

Araujo v. Ramirez-Limon, 490 So. 2d 1049 (Fla. 3d DCA 1986). · cites it 3×

Pereira v. Cutting Edge Landscaping & Servs. LLC (M.D. Fla. 2024). · cites it 8×

Tamayo v. Caballero, 413 So. 2d 78 (Fla. 3d DCA 1982). · cites it 2×

Monsour v. Bruce BALK, A.I.A., P.A., 705 So. 2d 968 (Fla. 2d DCA 1998). · cites it 2×

Raul J. Cepero a/k/a Raul De Jesus Cepero & Leslie Cepero v. The Bank of New York Mellon Trust Co. (Fla. 4th DCA 2016). · cites it 7× “They argued that this was not in compliance with section 48.031(2), Florida Statutes (2013).”

Gilbert v. Bayview Loan Servicing, LLC., 981 So. 2d 496 (Fla. 3d DCA 2008). · cites it 2×

Tamas Tibor Krisztian v. State Farm Mut. Auto. Ins. Co., as Subrogee of Renee M. Fiore (Fla. 4th DCA 2015). · cites it 11× “§ 48.031(6), Fla. Stat. (2012) (emphasis added); Clauro Enters.”

Cmty. Fed. Sav. & Loan v. Wright, 452 So. 2d 638 (Fla. 4th DCA 1984).

Epstein v. Brunel, 271 So. 3d 1173 (Fla. 3d DCA 2019). · cites it 6× “Instead, they attempted substitute service pursuant to section 48.031(2)(b): (b) Substitute service may be made on an individual doing business as a sole proprietorship at his or her place of business, during regular business hours, by serving the person in charge of the…”

Campbell v. ADW Consulting, LLC (M.D. Fla. 2024). · cites it 6×

Leister v. Legal Action Bureau, Inc. (M.D. Fla. 2024). · cites it 6×

Angarita v. Hypertoyz, Inc. (S.D. Fla. 2024). · cites it 6× “031(2)(b) in several respects,” Marabini fails to address, or even acknowledge, this Court’s previous findings, after a thorough analysis by both United States Magistrate Judge Jonathan Goodman and, thereafter, the District Court, that substitute service on Marabini at his place…”

Est. of Fernandez, 335 So. 2d 829 (Fla. 1976). · cites it 2×

Ward v. Gibson, 349 So. 2d 173 (Fla. 3d DCA 1976). · cites it 2×

Jones ex rel. Jones v. Lucks, 349 So. 2d 691 (Fla. 4th DCA 1977). · cites it 2×

La Rocca v. CSX Cloud LLC (M.D. Fla. 2022). · cites it 5×

Morancy v. Saloman (M.D. Fla. 2023). · cites it 5× “Section 48.031(6)(a) of the Florida Statutes provides for service upon individuals as follows: If the only address for a person to be served which is discoverable through public records is a private mailbox, a virtual office, or an executive office or mini suite, substitute…”

Kelly (N.D. Fla. 2026). · cites it 5×

Commodity Futures Trading Comm'n v. Notus LLC d/b/a ROFX, et al. (S.D. Fla. 2026). · cites it 5× “” Here, the CFTC served Konovalenko under Florida Statute § 48.031(6)(a) which provides for service on individuals as follows: If the only address for a person to be served which is discoverable through public records is a private mailbox, a virtual office, or an executive…”

Keneisha Smith & Javeous Ingram v. Florida Health Advisors, Inc., President Jason J. Monday, & John Doe Callers 1-10 (M.D. Fla. 2026). · cites it 5×

Jennifer Castaneda v. Portfolio Recovery Assocs., LLC (Fla. 4th DCA 2026). · cites it 5×

City of Sweetwater Florida v. St. Germain, 943 So. 2d 259 (Fla. 3d DCA 2006). · cites it 2×

Baker v. Joseph, 938 F. Supp. 2d 1265 (S.D. Fla. 2013). · cites it 2×

Falkner v. Pastrano, 251 So. 2d 712 (Fla. 3d DCA 1971). · cites it 2×

Shurman v. Atl. Mortg. & Inv., 740 So. 2d 1221 (Fla. 5th DCA 1999). · cites it 2×

Tamara Carus v. Cove at Isles at Bayshore Homeowners Ass'n, Inc. (Fla. 3d DCA 2022). · cites it 4×

Meredyth Capasso v. Mary Jo Buchanan & Herbert Bookstein (Fla. 4th DCA 2024). · cites it 4×

Gonzalez v. Solin (M.D. Fla. 2023). · cites it 4×

Caplan v. MALLORY (S.D. Fla. 2020). · cites it 4× “Service on Mallory Plaintiff contends that Mallory was properly served pursuant to section 48.031(2)(b), Florida Statutes. Section 48.”

Millennium Funding, Inc. v. 1701 Mgmt., LLC. (S.D. Fla. 2021). · cites it 4×

Viacao Itapemirim, S.A. (Bankr. S.D. Florida 2019). · cites it 4×

Atria Holdings, S.A. v. Atl. Funding Capital Corp. (M.D. Fla. 2024). · cites it 4×

Merritt v. Knowles (M.D. Fla. 2025). · cites it 4×

Orville Smith v. Alexandra Smith (Fla. 3d DCA 2026). · cites it 4×

Grosheim v. Greenpoint Mortg. Funding, Inc., 819 So. 2d 906 (Fla. 4th DCA 2002). · cites it 6×

Wright v. Sterling Drug, Inc., 321 So. 2d 460 (Fla. 2d DCA 1975). · cites it 2×

Matt Friedman v. Nicholas Schiano (11th Cir. 2019). · cites it 3×

Daniella Becker v. Timothy Becker (Fla. 3d DCA 2022). · cites it 3×

Taboada v. Mi Supermercado, LLC (M.D. Fla. 2019). · cites it 3×

Alvarez v. Gregory Hvac LLC (M.D. Fla. 2021). · cites it 3×

Stephenson v. Experian Info. Solutions, Inc. (M.D. Fla. 2023). · cites it 3×

Gs Holistic, LLC v. Prsn, LLC (M.D. Fla. 2023). · cites it 3×

Progressive Express Ins. Co. v. Smith (M.D. Fla. 2024). · cites it 3×

Angarita v. Hypertoyz, Inc. (S.D. Fla. 2023). · cites it 3×

Celebrity Actor's Camp, Inc., Winebarger v. McLaughlin, Bredbrenner (Fla. 2d DCA 2024). · cites it 3× “As provided for in section 48.031(6)(a), Florida Statutes (2022): If the only address for a person to be served which is discoverable through public records is a private mailbox, .”

Colonial Van Lines Inc. v. AAA Colonial Van Lines, Inc. (M.D. Fla. 2024). · cites it 3×

Eustache Inst. LLC v. Ward Photonics, LLC (M.D. Fla. 2024). · cites it 3×

GS Holistic, LLC v. Purple Haze of Seminole, LLC (M.D. Fla. 2023). · cites it 3×

Deppe (M.D. Fla. 2025). · cites it 3×

Core Distrib. v. The World Trade Corp., et al. (S.D. Fla. 2026). · cites it 3×

Walker v. Fifth Third Mortg. Co., 100 So. 3d 267 (Fla. 5th DCA 2012). · cites it 5×

Varn v. Varn, 16 Fla. Supp. 2d 58 (Fla. Palm Beach Cty. Ct. 1985). · cites it 7×

Black v. Black, 227 So. 2d 53 (Fla. 1st DCA 1969). · cites it 2×

Coffin v. Brandau, 614 F.3d 1240 (11th Cir. 2011). · cites it 4×

Brian Symonette v. Olga D. Lozano (Fla. 4th DCA 2021). · cites it 2×

In Re: Amendments to Florida Rule of Crim. Procedure 3.220, Florida Rule of Civil Procedure for Involuntary Commitment of Sexually Violent Predators 4.310, & Florida Rule of Juv. Procedure 8.060 (Fla. 2022). · cites it 2×

Jonathan Michael Schuler v. Sandy T. Fox, P.A. (Fla. 3d DCA 2022). · cites it 2×

Hencile Dorsey v. Kimberlee Jo Perretta, Etc. (Fla. 3d DCA 2023). · cites it 2×

Spencer C. Blanton v. Bd. of Cnty. Commissioners of Monroe Cnty., Florida (Fla. 3d DCA 2023). · cites it 2×

Indiana Farmers Mut. Ins. Co. v. Hernandez (M.D. Fla. 2020). · cites it 2×

Accident Ins. Co., Inc. v. V&A Drywall & Stucco, Inc. (M.D. Fla. 2020). · cites it 2×

Garrido v. Fiscella (M.D. Fla. 2021). · cites it 2×

Sanchez v. Marra Constr., Inc. (M.D. Fla. 2021). · cites it 2×

Milfort v. Rambosk (M.D. Fla. 2021). · cites it 2×

Peers v. U.S. Bank, N.A. (M.D. Fla. 2021). · cites it 2×

Halbig v. Lake Cnty., Florida (M.D. Fla. 2022). · cites it 2×

Shore v. 6th Jud. Circuit Court of Florida (M.D. Fla. 2023). · cites it 2×

Wagner v. Inmobiliaria Prop. Holdings Corp. (M.D. Fla. 2023). · cites it 2×

Beard v. Jacques (M.D. Fla. 2023). · cites it 2×

Cook v. State of Florida (M.D. Fla. 2023). · cites it 2×

Avraham v. Golden (D.N.J. 2020). · cites it 2×

Cash Wallace Pawley, Sr. v. First Nat'l Bank of South Miami, N.A. (Fla. 3d DCA 2024). · cites it 2×

In Re: Amendments to Florida Rules of Crim. Procedure - 2024 Legislation (Fla. 2024). · cites it 2×

UpEquity SPV1, LLC v. Glennon (M.D. Fla. 2024). · cites it 2×

Pastrana v. Carrington Mortg. Servs., LLC (M.D. Fla. 2024). · cites it 2×

Gaston v. City of Leesburg (M.D. Fla. 2024). · cites it 2×

Scott v. Wise Cnty. Dep't of Soc. Servs. (W.D. Va. 2021). · cites it 2×

Garcia v. Consum. Credit Union (S.D. Fla. 2024). · cites it 2×

Kanner v. Beverly, Jr. (M.D. Fla. 2024). · cites it 2×

Portes v. City of Doral (S.D. Fla. 2025). · cites it 2×

Merritt v. Knowles (M.D. Fla. 2025). · cites it 2×

In Re: Amendments to Florida Rules of Crim. Procedure 3.220, 3.851, & 3.853 (Fla. 2025). · cites it 2×

Hickman v. Jordan III (M.D. Fla. 2025). · cites it 2×

Porter v. Florida Boy Honey, LLC (M.D. Fla. 2025). · cites it 2×

Hoffman v. Jimenez (M.D. Fla. 2025). · cites it 2×

Nguida v. Lake Cnty. Sch. Dist. (M.D. Fla. 2025). · cites it 2×

GS Holistic, LLC v. Fumoo LLC d/b/a Fumoo Smoke Shop & Mehdi Ghounim (M.D. Fla. 2025). · cites it 2×

Sherwood (M.D. Fla. 2026). · cites it 2×

Heck v. Bank Liberty, 86 So. 3d 1281 (Fla. 1st DCA 2012). · cites it 3×

Silva v. BAC Home Loans Servicing, L.P., 60 So. 3d 555 (Fla. 5th DCA 2011). · cites it 2×

Stettner v. Richardson, 143 So. 3d 987 (Fla. 3d DCA 2014). · cites it 2×

Navarro v. Ocwen Loan Servicing, LLC, 148 So. 3d 522 (Fla. 2d DCA 2014). · cites it 2×

George Luis Toribio v. City of West Palm Beach, Florida, 171 So. 3d 813 (Fla. 4th DCA 2015). · cites it 2×

Davis v. Nat'l Collegiate Student Loan Trust 2004-2, 134 So. 3d 1065 (Fla. 4th DCA 2013). · cites it 2×

Jesson, Inc. v. Sutton Hill Assocs., Inc., 789 So. 2d 1064 (Fla. 4th DCA 2001). · cites it 2×

Gilbert v. Storey, 920 So. 2d 1173 (Fla. 3d DCA 2006). · cites it 2×

Palazzola v. Angel, 525 So. 2d 503 (Fla. 5th DCA 1988). · cites it 3× “" Section 48.031(2) provides that service of process of witness subpoenas are to be made as provided in section 48.”

Lopez v. Suarez, 773 So. 2d 572 (Fla. 3d DCA 2000). · cites it 3×

Bozorgmehr Pouyeh v. Pub. Health Trust of Jackson Health Sys. (11th Cir. 2017).

Suleymanov v. Winston Premier Logistics, LLC (D. Conn. 2023).

Daniel v. Concord Advice, LLC (M.D. Fla. 2020).

Brunett v. Nirvana Health Servs., Inc. (M.D. Fla. 2020).

Bachman v. Cognizant Bus. Servs. Corp. (M.D. Fla. 2020).

Joe Hand Promotions, Inc. v. Guevara (M.D. Fla. 2020).

United States v. Hall (M.D. Fla. 2021).

Wagner v. Salijanin, LLC (M.D. Fla. 2023).

FarFromBoringPromotions.Com v. Burrell-Campbell (S.D. Fla. 2020).

Av Grp. Boston, Inc. v. Avb Enter. LLC (S.D. Fla. 2022).

Walker v. Bubbly Brands LLC (N.D. Ga. 2021).

Dickson v. Artola (D.S.C. 2020).

Pereira v. Cutting Edge Landscaping & Servs. LLC (M.D. Fla. 2024).

Paul v. S.N.Y. Relocation Sys. Co. (D.N.M. 2024).

United States v. Ananayo (M.D. Fla. 2024).

Nordic Naturals, Inc. v. Premium Sellers LLC (N.D. Cal. 2025).

Ruiz-Paramo v. Aroma360 (D. Colo. 2025).

Skinner v. Galleon Companies LLC (M.D. Fla. 2025).

Hoffman v. Jimenez (M.D. Fla. 2025).

Nguida v. Lake Cnty. Sch. Dist. (M.D. Fla. 2025).

Vellar Holdings LLC v. USMPO LLC (S.D. Fla. 2025).

Garcia (S.D.N.Y. 2025).

Demetrius Jackson, Sr. v. Publix Super Markets Inc. (D.S.C. 2025).

Morales (M.D. Fla. 2025).

Navas Bar & Grill, Inc., D/B/A 1701 Restaurant & Lounge v. Tapias (Fla. 2d DCA 2025).

Scott (M.D. Fla. 2026).

Victorinox Swiss Army, Inc. v. Trade Channel LLC (D. Conn. 2026).

Lane (S.D. Miss. 2026).

Bellegue v. Fig Tree Corp., 21 Fla. Supp. 2d 57 (Fla. Volusia Cty. Ct. 1987). · cites it 2×

State v. Schewe, 28 Fla. Supp. 2d 121 (Fla. Cir. Ct. 1988). · cites it 2×

Washington v. State, 453 So. 2d 213 (Fla. 4th DCA 1984). · cites it 2×

Miller v. Johnson, 466 So. 2d 340 (Fla. 5th DCA 1985). · cites it 2×

Krasnow v. Eisenberg, 530 So. 2d 507 (Fla. 3d DCA 1988). · cites it 2×

Carr v. Glass-Tech Corp., 614 So. 2d 1227 (Fla. 3d DCA 1993). · cites it 2×

Gotlib v. Ponieman, 623 So. 2d 631 (Fla. 3d DCA 1993). · cites it 2×

State v. Rodriguez, 665 So. 2d 1148 (Fla. 3d DCA 1996). · cites it 2×

Rokeach v. Glickstein, 718 So. 2d 831 (Fla. 4th DCA 1998). · cites it 2×

In re the Marriage of Strauser, 297 So. 2d 856 (Fla. 4th DCA 1974). · cites it 2×

Stein v. Stein, 598 So. 2d 92 (Fla. 2d DCA 1992).

Liberman v. Gables Lightning Fixture Co., 241 So. 2d 449 (Fla. 3d DCA 1970).

Couts v. Maryland Cas. Co., 306 So. 2d 593 (Fla. 3d DCA 1975).

— 48.031(1) — 26 cases

Robles-Martinez v. Diaz, Reus & Targ, LLP, 88 So. 3d 177 (Fla. 3d DCA 2011). “Service made under the substitute service provisions of section 48.031, Florida Statutes, must be strictly complied with, and these provisions are to be strictly construed.”

Schupak v. Sutton Hill Assocs., 710 So. 2d 707 (Fla. 4th DCA 1998). “Service of process on appellant was attempted pursuant to section 48.031(1), Florida Statutes (1993), which provided: "service of original process is made by delivering a copy of it to the person to be served with a copy of the complaint .”

In Re Amendments to Fla. Rules Civ. Proc., 604 So. 2d 1110 (Fla. 1992). “Subdivision (c) is revised to conform with section 48.031, Florida Statutes (1979). RULE 1.”

Anthony v. Gary J. Rotella & Assocs., 906 So. 2d 1205 (Fla. 4th DCA 2005). “2d DCA 1993) (affirming the lower court's order quashing service of process because "service on the business manager does not satisfy the requirements for obtaining personal service on an individual pursuant to section 48.031, Florida Statutes (1991)").”

Magazine v. Bedoya, 475 So. 2d 1035 (Fla. 3d DCA 1985). “Magazine challenges the service arguing that: (1) his mother-in-law was not a "person residing therein" under section 48.031(1), Florida Statutes (Supp.”

Gamboa v. Jones, 455 So. 2d 613 (Fla. 3d DCA 1984).

In Re Amendments to Rules of Civ. Proc., 536 So. 2d 974 (Fla. 1988). “The summons form for personal service on natural persons is to be used for service on natural persons under the following provisions: Florida Statutes § 48.031 (service of process generally), § 48.”

Fundaro v. Canadiana Corp., 409 So. 2d 1099 (Fla. 4th DCA 1982).

Bache, Halsey, Stuart, Shields, Inc. v. Mendoza, 400 So. 2d 558 (Fla. 3d DCA 1981).

Hovarth v. Aetna Life Ins. Co., 634 So. 2d 240 (Fla. 5th DCA 1994).

Carlini v. State, Dept. of Legal Affairs, 521 So. 2d 254 (Fla. 4th DCA 1988).

Dep't of Revenue v. Wright, 813 So. 2d 989 (Fla. 2d DCA 2002).

Montano v. Montano, 472 So. 2d 1377 (Fla. 3d DCA 1985).

Henzel v. Noel, 598 So. 2d 220 (Fla. 5th DCA 1992). “However, Noel argues that since Henzel had deliberately attempted to avoid service of process, leaving the summons and complaint at Henzel's abode satisfied section 48.031. Noel relies, inter alia, on Haney v.”

Nettles v. White, 439 So. 2d 1048 (Fla. 2d DCA 1983).

Stoeffler v. Castagliola, 629 So. 2d 196 (Fla. 2d DCA 1993). “First, service on the business manager does not satisfy the requirements for obtaining personal service on an individual pursuant to section 48.031, Florida Statutes (1991). [1] The record does not support that Castagliola waived personal service, that he tried to evade service,…”

Johnston v. Halliday, 516 So. 2d 84 (Fla. 3d DCA 1987).

Willoughby v. Seese Realty Inc., 421 So. 2d 691 (Fla. 4th DCA 1982).

Burtchaell v. Hoffman, 508 So. 2d 738 (Fla. 5th DCA 1987).

Araujo v. Ramirez-Limon, 490 So. 2d 1049 (Fla. 3d DCA 1986).

Grosheim v. Greenpoint Mortg. Funding, Inc., 819 So. 2d 906 (Fla. 4th DCA 2002).

Varn v. Varn, 16 Fla. Supp. 2d 58 (Fla. Palm Beach Cty. Ct. 1985).

Jesson, Inc. v. Sutton Hill Assocs., Inc., 789 So. 2d 1064 (Fla. 4th DCA 2001).

Palazzola v. Angel, 525 So. 2d 503 (Fla. 5th DCA 1988). “" Section 48.031(2) provides that service of process of witness subpoenas are to be made as provided in section 48.”

Krasnow v. Eisenberg, 530 So. 2d 507 (Fla. 3d DCA 1988).

Stein v. Stein, 598 So. 2d 92 (Fla. 2d DCA 1992).

— 48.031(1)(a) — 54 cases

Shurman v. Atl. Mortg. & Inv. Corp., 795 So. 2d 952 (Fla. 2001). “Following an evidentiary hearing on Shurman's motion, the trial court concluded that Shurman's "usual place of abode" for purposes of serving process under section 48.031, Florida Statutes (1997), was the residence where he lived with his wife prior to his incarceration and…”

Florida Dep't of Child. & Families v. Sun-Sentinel, Inc., 865 So. 2d 1278 (Fla. 2004). “" Section 48.031(1)(a), Florida Statutes (2002), states that "[s]ervice of original process is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading.”

Carter v. Lil'Joe Records, Inc., 829 So. 2d 953 (Fla. 4th DCA 2002). “In addition to the procedure set forth in section 48.031, this state has specifically set forth the proper method for service of process on prisoners.”

Gilliam v. Smart, 809 So. 2d 905 (Fla. 1st DCA 2002). “[3] Pursuant to section 48.031(1)(a), Florida Statutes (2001), Gilliam was served on March 14, 2001, at his usual place of abode with a person residing therein, his mother, who was over 15 years of age.”

Williams v. Nuno, 239 So. 3d 153 (Fla. 3d DCA 2018). “Bryan Williams a/k/a “Birdman” (“the defendant”) appeals a non-final order denying his supplemental motion to dismiss the complaint based on insufficiency of service of process, asserting that, contrary to the return of service, the person the process server gave the summons and…”

Torres v. Arnco Const., Inc., 867 So. 2d 583 (Fla. 5th DCA 2004). “, was properly served with process by substitute service pursuant to section 48.031, Florida Statutes (2002). Specifically, Mr.”

Boatfloat, LLC v. Cent. Transp. Intern., 941 So. 2d 1271 (Fla. 4th DCA 2006). “Where, however, the person to be served flees from the presence of the process server in a deliberate attempt to avoid service of process, the delivery requirement of .”

Chapman v. Sheffield, 750 So. 2d 140 (Fla. 1st DCA 2000).

Cordova v. Jolcover, 942 So. 2d 1045 (Fla. 2d DCA 2006). “Cordova argues that the trial court lacked personal jurisdiction over him because he was not served with process at his usual place of abode as required by section 48.031, Florida Statutes (2004). Because Mr.”

Berne v. Beznos, 819 So. 2d 235 (Fla. 3d DCA 2002).

Cason Ex Rel. Saferight v. Hammock, 908 So. 2d 512 (Fla. 5th DCA 2005).

Smith v. Cuban Am. Nat'l Found., 657 So. 2d 86 (Fla. 3d DCA 1995).

SH v. Dep't of Child. & Families, 837 So. 2d 1117 (Fla. 4th DCA 2003).

Busman v. State, Dept. of Revenue, 905 So. 2d 956 (Fla. 3d DCA 2005).

Monsour v. Balk, 705 So. 2d 968 (Fla. 2d DCA 1998).

Sadlak v. Nationstar Mortg., 252 So. 3d 302 (Fla. 3d DCA 2018). “” § 48.031(a)(1), Fla. Stat. (2016). Service must be done in this manner, and the return must include the following information: Each person who effects service of process shall note on a return-of- service form attached thereto, the date and time when it comes to hand, the date…”

Weiss v. Mashantucket Pequot Gaming Enter., 935 So. 2d 69 (Fla. 3d DCA 2006).

Kemmerer v. Klass Assocs., Inc., 108 So. 3d 672 (Fla. 2d DCA 2013).

Green v. Jorgensen, 56 So. 3d 794 (Fla. 1st DCA 2011).

Aero Costa Rica, Inc. v. Dispatch Servs., Inc., 710 So. 2d 218 (Fla. 3d DCA 1998).

Woide v. Fannie Mae, 116 So. 3d 1281 (Fla. 5th DCA 2013).

Portfolio Recovery Assocs., LLC v. Gonzalez, 951 So. 2d 1037 (Fla. 3d DCA 2007).

Monsour v. Bruce BALK, A.I.A., P.A., 705 So. 2d 968 (Fla. 2d DCA 1998).

Gilbert v. Bayview Loan Servicing, LLC., 981 So. 2d 496 (Fla. 3d DCA 2008).

Jennifer Castaneda v. Portfolio Recovery Assocs., LLC (Fla. 4th DCA 2026).

City of Sweetwater Florida v. St. Germain, 943 So. 2d 259 (Fla. 3d DCA 2006).

Raul J. Cepero a/k/a Raul De Jesus Cepero & Leslie Cepero v. The Bank of New York Mellon Trust Co. (Fla. 4th DCA 2016). “They argued that this was not in compliance with section 48.031(2), Florida Statutes (2013).”

Jonathan Michael Schuler v. Sandy T. Fox, P.A. (Fla. 3d DCA 2022).

Tamara Carus v. Cove at Isles at Bayshore Homeowners Ass'n, Inc. (Fla. 3d DCA 2022).

Indiana Farmers Mut. Ins. Co. v. Hernandez (M.D. Fla. 2020).

Pereira v. Cutting Edge Landscaping & Servs. LLC (M.D. Fla. 2024).

Nguida v. Lake Cnty. Sch. Dist. (M.D. Fla. 2025).

Core Distrib. v. The World Trade Corp., et al. (S.D. Fla. 2026).

George Luis Toribio v. City of West Palm Beach, Florida, 171 So. 3d 813 (Fla. 4th DCA 2015).

Epstein v. Brunel, 271 So. 3d 1173 (Fla. 3d DCA 2019). “Instead, they attempted substitute service pursuant to section 48.031(2)(b): (b) Substitute service may be made on an individual doing business as a sole proprietorship at his or her place of business, during regular business hours, by serving the person in charge of the…”

Taboada v. Mi Supermercado, LLC (M.D. Fla. 2019).

Brunett v. Nirvana Health Servs., Inc. (M.D. Fla. 2020).

Bachman v. Cognizant Bus. Servs. Corp. (M.D. Fla. 2020).

Joe Hand Promotions, Inc. v. Guevara (M.D. Fla. 2020).

Accident Ins. Co., Inc. v. V&A Drywall & Stucco, Inc. (M.D. Fla. 2020).

Alvarez v. Gregory Hvac LLC (M.D. Fla. 2021).

Wagner v. Inmobiliaria Prop. Holdings Corp. (M.D. Fla. 2023).

Gs Holistic, LLC v. Prsn, LLC (M.D. Fla. 2023).

FarFromBoringPromotions.Com v. Burrell-Campbell (S.D. Fla. 2020).

Pereira v. Cutting Edge Landscaping & Servs. LLC (M.D. Fla. 2024).

Colonial Van Lines Inc. v. AAA Colonial Van Lines, Inc. (M.D. Fla. 2024).

Paul v. S.N.Y. Relocation Sys. Co. (D.N.M. 2024).

GS Holistic, LLC v. Purple Haze of Seminole, LLC (M.D. Fla. 2023).

Paul v. S.N.Y. Relocation Sys. Co. (D.N.M. 2024).

Nguida v. Lake Cnty. Sch. Dist. (M.D. Fla. 2025).

— 48.031(1)(b) — 1 case

Curtis Sherrod II, et. al. v. Briar Bay Ass'n, et. al. (S.D. Fla. 2025). “The Court finds that § 48.031(1)(b) does not apply here for two reasons.”

— 48.031(2) — 3 cases

Raul J. Cepero a/k/a Raul De Jesus Cepero & Leslie Cepero v. The Bank of New York Mellon Trust Co., 189 So. 3d 204 (Fla. 4th DCA 2016). “They argued that this was not in compliance with section 48.031(2), Florida Statutes (2013).”

Palazzola v. Angel, 525 So. 2d 503 (Fla. 5th DCA 1988). “" Section 48.031(2) provides that service of process of witness subpoenas are to be made as provided in section 48.”

— 48.031(2)(B) — 1 case

Angarita v. Hypertoyz, Inc. (S.D. Fla. 2024). “031(2)(b) in several respects,” Marabini fails to address, or even acknowledge, this Court’s previous findings, after a thorough analysis by both United States Magistrate Judge Jonathan Goodman and, thereafter, the District Court, that substitute service on Marabini at his place…”

— 48.031(2)(a) — 3 cases

Frank Romeo & Connie Yang v. US Bank Nat'l Ass'n, 144 So. 3d 585 (Fla. 4th DCA 2014). “Section 48.031, Florida Statutes (2013), governs service of process.”

— 48.031(2)(b) — 5 cases

Myrick v. Walters, 666 So. 2d 249 (Fla. 2d DCA 1996). “Further, a potential problem arises with the return of service in that it indicates that the summons and complaint were served on the assistant manager of Big Tim's Bar BQ, in seeming contravention of section 48.031(2)(b), Florida Statutes (1989).”

Vidal v. SunTrust Bank, 41 So. 3d 401 (Fla. 4th DCA 2010). “” Along similar lines, service made pursuant to section 48.031(2)(b) allows substitute service on a sole proprietorship at his or her place of business during regular business hours.”

Caplan v. MALLORY (S.D. Fla. 2020). “Service on Mallory Plaintiff contends that Mallory was properly served pursuant to section 48.031(2)(b), Florida Statutes. Section 48.”

— 48.031(3)(b) — 3 cases

In Re Amendments to the Florida Rules of Crim. Procedure & Florida Rule of Appellate Procedure 9.140, 176 So. 3d 980 (Fla. 2015). “Amended section 48.031(3)(b) allows a criminal witness subpoena for appearance for a deposition to be “posted by a person authorized to serve process at the witness’s residence if one attempt to serve .”

— 48.031(4) — 1 case

Rodriguez v. State, 919 So. 2d 1252 (Fla. 2006). “The judge explained that Rodriguez had served the subpoenas on these witnesses only one day before the hearing and the witnesses rightly claimed that their attendance was an undue burden and a violation of section 48.031(4), Florida Statutes (1995), which governs service of…”

— 48.031(4)(a)(3) — 1 case

— 48.031(5) — 9 cases

Nirk v. Bank of Am., N.A., 94 So. 3d 658 (Fla. 4th DCA 2012). “” § 48.031(5), Fla. Stat. (2010) (emphasis added).”

David Davidian & Irma Davidian v. JP Morgan Chase Bank, Nat'l Ass'n, 178 So. 3d 45 (Fla. 4th DCA 2015). “They were shown to comply with section 48.031 and 48.21, Florida Statutes (2015).”

James Matthews & Roberta Matthews v. U.S. Bank, Nat'l Ass'n, etc., 197 So. 3d 1140 (Fla. 4th DCA 2016). “” § 48.031, Fla. Stat. (2015). Appellants contend that the summonses contain illegible handwritten notations.”

Roy L. Lilly v. Bank of Am., N.A., 267 So. 3d 452 (Fla. 4th DCA 2019). “4th DCA 2012) (holding that section 48.031(5), Florida Statutes (2010) required the information to appear on the copy of the summons); see also Romeo v.”

Schofield v. Wells Fargo Bank, N.A., 95 So. 3d 1051 (Fla. 5th DCA 2012).

Brown v. U.S. Bank Nat'l Ass'n, 117 So. 3d 823 (Fla. 4th DCA 2013).

Meredyth Capasso v. Mary Jo Buchanan & Herbert Bookstein (Fla. 4th DCA 2024).

Walker v. Fifth Third Mortg. Co., 100 So. 3d 267 (Fla. 5th DCA 2012).

— 48.031(6) — 8 cases

Beckley v. Best Restorations, Inc., 13 So. 3d 125 (Fla. 4th DCA 2009). “We reverse the trial court’s order denying the Defendants’ cross-motion to quash service of process because section 48.031(6), Florida Statutes (2008) was not a valid method for the Plaintiff to serve the Defendants.”

Clauro Enter., Inc. v. Aragon Galiano Holdings, LLC, 16 So. 3d 1009 (Fla. 3d DCA 2009). “Pursuant to section 48.031(6), Florida Statutes (2008), Aragon attempted service on both Clauro and Rupcich by leaving copies of the complaint and summons with the owner of a UPS mailbox store located in Weston, Florida.”

McDaniel v. FirstBank Puerto Rico, 96 So. 3d 926 (Fla. 2d DCA 2012). “Because the requirements of section 48.031(6), Florida Statutes (2010), were not met in effectuating substitute service against the McDan-iels, we reverse the order denying the motion to quash.”

TID Servs., Inc. v. Dass, 65 So. 3d 1 (Fla. 2d DCA 2010). “3d DCA 2009) (outlining the conditions under which service at a private mailbox under section 48.031(6) is permitted). Here, Mr.”

Tamas Tibor Krisztian v. State Farm Mut. Auto. Ins. Co., as Subrogee of Renee M. Fiore (Fla. 4th DCA 2015). “§ 48.031(6), Fla. Stat. (2012) (emphasis added); Clauro Enters.”

Curtis Sherrod II, et. al. v. Briar Bay Ass'n, et. al. (S.D. Fla. 2025). “The Court finds that § 48.031(1)(b) does not apply here for two reasons.”

La Rocca v. CSX Cloud LLC (M.D. Fla. 2022).

Celebrity Actor's Camp, Inc., Winebarger v. McLaughlin, Bredbrenner (Fla. 2d DCA 2024). “As provided for in section 48.031(6)(a), Florida Statutes (2022): If the only address for a person to be served which is discoverable through public records is a private mailbox, .”

— 48.031(6)(a) — 7 cases

Coutts v. Sabadell United Bank, N.A., 199 So. 3d 1099 (Fla. 3d DCA 2016). “2015), wherein the court addressed whether “the specifics regarding the manner of service as set forth in section 48.031 must be indicated in a valid return of service.”

Morancy v. Saloman (M.D. Fla. 2023). “Section 48.031(6)(a) of the Florida Statutes provides for service upon individuals as follows: If the only address for a person to be served which is discoverable through public records is a private mailbox, a virtual office, or an executive office or mini suite, substitute…”

Commodity Futures Trading Comm'n v. Notus LLC d/b/a ROFX, et al. (S.D. Fla. 2026). “” Here, the CFTC served Konovalenko under Florida Statute § 48.031(6)(a) which provides for service on individuals as follows: If the only address for a person to be served which is discoverable through public records is a private mailbox, a virtual office, or an executive…”

Leister v. Legal Action Bureau, Inc. (M.D. Fla. 2024). “§ 48.031(6)(a). The Court accepts the process server’s statement that the address for the registered agent was residential.”

La Rocca v. CSX Cloud LLC (M.D. Fla. 2022).

Jayakumar v. Osinkowska (S.D. Fla. 2023).

— 48.031(a)(1) — 1 case

— 48.031(l)(a) — 26 cases

Lance Koster v. Carol Sullivan, 160 So. 3d 385 (Fla. 2015). “The pertinent portion of section 48.031 provided: 48.031 Service of process generally; service of witness subpoenas.”

Koster v. Sullivan, 103 So. 3d 882 (Fla. 2d DCA 2012). “The Third District has suggested that “[s]ervice made under the substitute service provisions of section 48.031 ... must be strictly complied with and [that] these provisions are to be strictly construed.”

Nirk v. Bank of Am., N.A., 94 So. 3d 658 (Fla. 4th DCA 2012). “” § 48.031(5), Fla. Stat. (2010) (emphasis added).”

David Davidian & Irma Davidian v. JP Morgan Chase Bank, Nat'l Ass'n, 178 So. 3d 45 (Fla. 4th DCA 2015). “They were shown to comply with section 48.031 and 48.21, Florida Statutes (2015).”

Johnston v. HUDLETT, 32 So. 3d 700 (Fla. 4th DCA 2010). “Johnston’s counsel, and Sandra Johnston was defaulted as to the material allegations of the complaint.”

Baker v. Stearns Bank, N.A., 84 So. 3d 1122 (Fla. 2d DCA 2012). “3d DCA 2011) (“Service made under the substitute service provisions of section 48.031, Florida Statutes, must be strictly complied with, and these provisions are to *1126 be strictly construed.”

Conax Florida Corp. v. Astrium Ltd., 499 F. Supp. 2d 1287 (M.D. Fla. 2007). “The plaintiff contends that it properly effected personal service of process upon the defendant pursuant to § 48.031, Fla. Stat., and substitute service under §§ 48.”

Ingenieria Y Exportacion De Tecnologia S.L. v. Freytech, Inc., 210 So. 3d 211 (Fla. 2d DCA 2016).

Pace v. Bank of New York Mellon Trust Co., 224 So. 3d 342 (Fla. 5th DCA 2017).

Carone v. Millennium Settlements, Inc., 84 So. 3d 1141 (Fla. 4th DCA 2012).

Vives v. Wells Fargo Bank, N.A., 128 So. 3d 9 (Fla. 3d DCA 2012).

Frank Romeo & Connie Yang v. US Bank Nat'l Ass'n, 144 So. 3d 585 (Fla. 4th DCA 2014). “Section 48.031, Florida Statutes (2013), governs service of process.”

Janet Mauro & Dennis Quinn v. Wells Fargo Bank, N.A., 180 So. 3d 1083 (Fla. 4th DCA 2015).

Chancelor v. BWC Investments, 57 So. 3d 969 (Fla. 4th DCA 2011).

Griffith v. Slade, 95 So. 3d 982 (Fla. 2d DCA 2012).

Shurman v. Atl. Mortg. & Inv., 740 So. 2d 1221 (Fla. 5th DCA 1999).

Stettner v. Richardson, 143 So. 3d 987 (Fla. 3d DCA 2014).

Gilbert v. Storey, 920 So. 2d 1173 (Fla. 3d DCA 2006).

Lopez v. Suarez, 773 So. 2d 572 (Fla. 3d DCA 2000).

Rokeach v. Glickstein, 718 So. 2d 831 (Fla. 4th DCA 1998).

Heck v. Bank Liberty, 86 So. 3d 1281 (Fla. 1st DCA 2012).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.