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Illinois Compiled Statutes

735 ILCS 5/2-203.1 (2026)

Service by special order of court

✓ current as of May 2026
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(735 ILCS 5/2-203.1) (from Ch. 110, par. 2-203.1)
    Sec. 2-203.1. Service by special order of court. If service upon an individual defendant is impractical under items (1) and (2) of subsection (a) of Section 2-203, the plaintiff may move, without notice, that the court enter an order directing a comparable method of service. The motion shall be accompanied with an affidavit stating the nature and extent of the investigation made to determine the whereabouts of the defendant and the reasons why service is impractical under items (1) and (2) of subsection (a) of Section 2-203, including a specific statement showing that a diligent inquiry as to the location of the individual defendant was made and reasonable efforts to make service have been unsuccessful. The court may order service to be made in any manner consistent with due process.
(Source: P.A. 87-1165.)

    
Notes of Decisions
Cited in 23 cases (7 in the last 5 years), 2004–2026 · leading case: People Ex Rel. Waller v. Harrison, 810 N.E.2d 589 (Ill. App. Ct. 2d Dist. 2004).
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People Ex Rel. Waller v. Harrison, 810 N.E.2d 589 (Ill. App. Ct. 2d Dist. 2004). · cites it 5× “The motion must be accompanied by an affidavit "stating the nature and extent of the investigation made to determine the whereabouts of the defendant and the reasons why service is impractical under items (1) and (2) of subsection (a) of Section 2-203, including a specific…”
Sutton v. Ekong, 2013 IL App (1st) 121975, 994 N.E.2d 589. · cites it 2× “1 of the Code of Civil Procedure (735 ILCS 5/2-203.1 (West 2008)). Plaintiff asserted that she had been diligent in attempting to serve Ekong and that the inability to effect service upon him showed that he was evading service.”
Citimortgage, Inc. v. Cotton, 2012 IL App (1st) 102438, 977 N.E.2d 255. “1 of the Code (735 ILCS 5/2-203.1 (West 2008)), which permits the court to order an alternative method of service upon plaintiff’s motion and an affidavit stating that personally serving the defendant is impractical, including a specific statement showing that upon due inquiry…”
Silverberg v. Haji, 2015 IL App (1st) 141321. · cites it 2× “1 of the Code of Civil Procedure (Code) (735 ILCS 5/2-203.1 (West 2010)), which allows the court to permit service by an alternative method when the standard service methods are impractical.”
Chung v. Pham, 2020 IL App (3d) 190218. “735 ILCS 5/2-203.1 (West 2014). Sonny’s attorney of record was served with a copy of the verified complaint filed in the underlying lawsuit on April 21, 2015.”
Silverberg v. Haji, 2015 IL App (1st) 141321, 33 N.E.3d 957. · cites it 2× “1 of the Code of Civil Procedure (Code) (735 ILCS 5/2-203.1 (West 2010)), which allows the court to permit service by an alternative method when the standard service methods are impractical.”
Thompson v. Ross Dialysis-Englewood, LLC, 2017 IL App (1st) 161329. · cites it 2× “1 of the Code of Civil Procedure (Code) (735 ILCS 5/2-203.1 (West 2014)), claiming that he had incurred “significant expense attempting to locate and personally serve [Braggs], however [p]laintiff has been unable to serve [Braggs].”
Corlis v. Edelberg, 2018 IL App (1st) 170049, 117 N.E.3d 551. “See 735 ILCS 5/2-203.1 (West 2016) ("The motion shall be accompanied with an affidavit stating the nature and extent of the investigation made to determine the whereabouts of the defendant and the reasons why service is impractical under items (1) and (2) of subsection (a) of…”
O'Halloran v. Luce, 2013 IL App (1st) 113735, 988 N.E.2d 156. · cites it 2× “1 of the Illinois Code of Civil Procedure (Code) (735 ILCS 5/2-203.1 (West 2010)). Specifically, O’Halloran requested the court’s permission to serve Luce by publication.”
Thompson v. Ross Dialysis-Englewood, LLC, 2017 IL App (1st) 161329. · cites it 2× “1 of the Code of Civil Procedure (Code) (735 ILCS 5/2-203.1 (West 2014)), claiming that he had incurred “significant expense attempting to locate and personally serve [Braggs], however [p]laintiff has been unable to serve [Braggs].”
Urban P'ship Bank v. Ragdale, 2017 IL App (1st) 160773. “735 ILCS 5/2-203.1 (West 2014). A motion for service brought pursuant to section 2-203.”
Enns v. Jackson, 2020 IL App (5th) 190538-U. “1 of the Code (735 ILCS 5/2-203.1 (West 2018)) and section 10-301(b) of the Illinois Vehicle Code (Vehicle Code) (625 ILCS 5/10-301(b) (West 2018)) as the applicable law.”
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