Plaintiff was injured in a chain of rear-end collisions. She sued three drivers, eventually settling with two of them. Service upon the third defendant was unsuccessfully attempted on six occasions. Plaintiff then obtained an order permitting service through the Secretary of State, a procedure available for cases against non-residents. A default judgment was entered, and eventually the court awarded $199,998.32 in damages. Plaintiff then filed a citation to discover assets personally obtaining service on the defendant at his place of employment. Defendant filed a motion to vacate which was denied.

The First District reversed. Although plaintiff made six attempts to serve the defendant at his residence, she did not dispute that the defendant's business address was in the phone book and could easily have been obtained. It concluded plaintiff did not conduct a diligent inquiry into the defendant's whereabouts prior to requesting service by special order of the court. As service through the Secretary of State by special order of the court was improper, there was no jurisdiction over the defendant, and the judgment was void. Sutton v. Ekong, 2013 IL App (1st) 121975.