Substituted Service Under MCR 2.105

Published 2026-05-10 by Papers Delivered (Process Servers).

What MCR 2.105 Allows

Michigan Court Rule 2.105 governs service of process in civil cases. Subrules (A) through (H) cover the standard service methods (personal, to a registered agent, to a corporation, etc.). When those methods fail, MCR 2.105(I)(1) allows the court, on motion, to authorize alternative service:

"On a showing that service of process cannot reasonably be made as provided by this rule, the court may by order permit service of process to be made in any other manner reasonably calculated to give the defendant actual notice of the proceedings and an opportunity to be heard."

The Two-Pronged Standard

To grant the motion, the court must find:

1. Reasonable diligence -- you tried the standard methods and they failed.
2. Reasonably calculated to give actual notice -- your proposed alternative is likely to actually reach the defendant.

Both prongs require evidence. A weak affidavit on either prong gets the motion denied -- which adds weeks to your timeline and forces you to resume attempts under the original methods.

Drafting the Affidavit

The affidavit attached to your MCR 2.105(I) motion is the heart of the case. Judges expect:

• Date, time, and outcome of every attempt -- not vague "I tried multiple times" but specific entries
• Observations at each attempt -- vehicles in driveway, lights on inside, mail boxes full or empty
• Address verification -- skip-trace results, voter rolls, vehicle registrations confirming the defendant lives there
• Alternate-attempt history -- did you try certified mail? Did you try the workplace?
• Proposed alternate method with reasoning -- e.g., "social media is reasonably calculated because defendant maintains active accounts and has acknowledged service-related messages there"

Common Alternate Methods Granted

• Posting + first-class mail -- by far the most common. Post the documents on the door, mail by USPS, file proof.
• Certified mail with return receipt -- often combined with posting.
• Service by publication -- typically once a week for three weeks in a newspaper of general circulation in the county. Required for some matters (e.g., quiet title against unknown heirs).
• Service via social media or email -- granted in narrow cases where the defendant uses those channels actively. Recent Michigan precedent supports it for known-active accounts.
• Service on a relative or known associate -- if records show the defendant resides with or contacts that person regularly.

Substituted Service vs Alternate Service -- Don't Conflate

Substituted service under MCR 2.105(A)(2) is a regular service method: you can leave documents at the defendant's usual place of abode with a person of suitable age and discretion, plus mail. You don't need a court order.

Alternate service under MCR 2.105(I) requires a motion and order before you can serve. Mixing the two terminologies in your motion confuses the court.

How a Process Server Helps

Most failed MCR 2.105(I) motions fail because the affidavit lacks specifics. Our affidavits include audio/video time stamps, GPS coordinates, defendant-vehicle plates, observed lights and movement, and direct quotes from anyone who came to the door. That level of detail makes the motion almost a formality -- judges grant it from the bench.

Related

• When the Defendant Avoids Service
• Skip Tracing for Michigan Civil Cases
• MCL 750.539c Audio Recording