James L. Steward, Jr., Appellant v. Adam Kuettel, Appellee

Summary

The court held that the default judgment was void because the email-based alternative service ordered by the circuit court was not reasonably calculated under the circumstances to provide actual notice of the lawsuit. Because service was constitutionally insufficient, the court reversed the denial of Steward’s motion to set aside the default judgment and did not reach his alternative mistake-or-excusable-neglect argument.