Cox v. Quigley
United States District Court for the District of Maine
141 F.R.D. 222 (D. Me 1992)
Quigley (defendant), who spent much of his time at sea with the Military Sealift Command and split remaining time between relatives in New York, Florida, and Maine, changed his official residence to Florida for tax purposes; Cox (plaintiff) attempted to serve him by leaving process with his father at a New York address where Quigley's father said Quigley did not actually live, then mailing a copy there. When Quigley failed to appear, a default judgment was entered, and Quigley moved to vacate it for lack of personal jurisdiction due to inadequate service.
Whether a transient defendant may be served by leaving a copy of the summons and complaint at the home of the defendant's parents.