Summary
State v. Vahl, 56 Wn. App. 603, 784 P.2d 1280 (1990)
Facts
The Department of Licensing sent Vahl notice by certified mail that she was a habitual offender and that her license would be revoked. According to State statute, the notice was sent to an address shown in the department records at that time. Three years later, a police officer stopped Vahl and cited her with driving in violation of an order revoking her license. The citation showed a different address than the one maintained by the Department.
Judicial History
Vahl was charged with driving in violation of an order revoking her license. Defense moved to dismiss for lack of evidence that she received notice of revocation. The court denied the motion.
Specific Issue
Whether notice sent by certified mail to the address of record maintained by the department is sufficient notice. Yes
Holding
Notice by certified mail to the address as shown in department records at the time of mailing is sufficient notice.
Reasoning
Refusing to claim certified mail is analogous to refusing in hand service of process. A person who refuses to accept service of process cannot prevent a proper court from obtaining jurisdiction.
C4PSE Comment
This case demonstrates the relative ease with which notice requirements can be reduced to the simple use of the mail system or, in the alternative, the Internet and its associated features such as e-mail, social networking, and instant messaging. If a statute is created or amended in such a manner as to allow personal service by one of these alternative means then the requirement for in-hand service may well disappear.