In Scanlan v. Townsend, No. 89853-7, the Washington Supreme Court held that second-hand service of process — the process server delivered a copy of the summons and complaint to the home of defendant’s father, who later handed the summons and complaint to the defendant within the statute of limitations — met the requirements of personal service under RCW 4.28.080(15). RCW 4.28.080(15) authorizes serving the summons and complaint on the defendant personally, or by substitute service, by “leaving a copy . . . at the house of his or her usual abode with some person of suitable age and discretion then resident therein.” CR 4(c) provides that “any person over 18 years of age who is competent to be a witness in the action, other than a party” may serve process. The Court held that defendant’s father met these criteria and served his daughter with process, albeit inadvertently, by handing her the summons and complaint.
