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Affidavit of Service / Return of Service

The sworn statement by the process server confirming personal or substituted service of the foreclosure complaint.

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Affidavits & Declarations

An Affidavit of Service (also called Return of Service or Proof of Service) is the sworn statement by the process server confirming that the foreclosure Summons and Complaint were properly served on the defendant. In judicial foreclosure, the court needs proof that the defendant was served with process — without proper service, the court lacks personal jurisdiction and any judgment is void. The affidavit must specify: the documents served (Summons, Complaint, Lis Pendens), the date and time of service, the manner of service (personal delivery, substituted service at the dwelling with a person of suitable age and discretion, or service by publication), the person served (name and description), and the process server's license/registration number. Defects in service — sewer service (process server throws the papers in the sewer and lies), service on the wrong person, service at the wrong address, or improper substituted service — are grounds to vacate a default judgment and dismiss the foreclosure.

Purpose

  • 1Prove that the defendant was served with process in accordance with state law
  • 2Establish personal jurisdiction over the defendant
  • 3Document the date, time, and manner of service for the court record

Who Prepares It

A licensed/certified process server (or the Sheriff's office) prepares the Affidavit of Service and files it with the court.

When It Is Used

Filed in every judicial foreclosure after service of the Summons and Complaint. Filed before the court can enter a default judgment (to prove jurisdiction).

Legal Effect

The Affidavit of Service is prima facie evidence of proper service (creates a presumption). A defendant can challenge service through a Motion to Vacate Default Judgment, asserting improper service and lack of personal jurisdiction. If the court finds service was improper, the default judgment is void and the foreclosure must be re-filed (or the defendant can defend on the merits). Sewer service — deliberate failure to serve combined with a false affidavit — is fraud on the court.

Common Mistakes

Not challenging improper service — if you were never served but a default judgment was entered, file a Motion to Vacate immediately
Not checking the description of the person served — if the affidavit describes someone of a different race, age, or gender than anyone in your household, it may be false
Assuming service by publication is valid — service by publication is a last resort allowed only after diligent efforts to locate the defendant; challenge the 'diligent search' if you were findable

Homeowner Rights

Right to proper service of the Summons and Complaint in accordance with state law
Right to challenge improper service (Motion to Vacate Default Judgment, Motion to Dismiss for Insufficient Service)
Right to a hearing on the issue of improper service
Right to assert lack of personal jurisdiction if service is void

Frequently Asked Questions

What is 'sewer service' and what can I do about it?

Sewer service is when a process server claims to have served you (or someone at your home) but actually threw the papers away or falsified the affidavit. It was widespread during the foreclosure crisis. If a default judgment was entered against you and you were never served: (1) immediately file a Motion to Vacate Default Judgment, (2) provide evidence you were never served (testimony, proof you were at work/home elsewhere at the time alleged, description of the person allegedly served does not match anyone in your household), (3) seek an order dismissing the foreclosure for lack of jurisdiction, and (4) consider filing a complaint against the process server's license.

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