Equity Residential v. Nasolo (2006)

Equity Residential v. Nasolo (2006)

Mr. Ring successfully defended a tenant who was not properly served against a landlord’s eviction suit. Here, although the landlord’s process server made four attempts at service on weekdays over a six-day period, the landlord made no attempt to locate the tenant. The landlord then served the tenant by publication and obtained an eviction order. Upon joining the case as the tenant’s counsel, Mr. Ring successfully argued on appeal that an investigation into the whereabouts of a putative defendant is required before a plaintiff can resort to service by publication. The Appellate Court held that strict compliance with every requirement of the service statute is mandated before constructive service may be used. This holding changed the way service by publication was used in Illinois, imposing greater requirements on plaintiffs to protect defendants from gamesmanship in service of process.