Hukill v. Oklahoma Native American Domestic Violence Coalition

Sheree Hukill (plaintiff) sued her former employer and its director, Pauline Musgrove (defendants), and served process by certified mail under Oklahoma's Rule 4-authorized method, which requires delivery restricted to the addressee; the mailing to Musgrove was marked restricted delivery but was delivered to an unauthorized recipient, and the mailing to the organization was not marked restricted delivery at all and was likewise accepted by someone not authorized to receive it. When the defendants failed to respond, the court entered default judgment; the defendants moved to set it aside as void for defective service, without denying they had actual notice of the suit. The district court found Oklahoma law required only substantial compliance and upheld the judgment, and the defendants appealed.