Flowers

INTRODUCTION

Marianne Flowers alleged she was injured when she slipped and fell on water from a freezer leak at a Vons supermarket. Among other defendants, she sued Jerry Crawford, the president and CEO of a janitorial company. She did so as a self-represented litigant. More than two years after filing her complaint, Flowers allegedly served the summons and complaint on Crawford by substituted service. She failed to show proof she mailed Crawford a copy of the summons and complaint by first-class mail, as required by California

Code of Civil Procedure section 415.20, subdivision (b).1 Instead, she filed proof of service that she emailed a copy of the summons and complaint to Crawford’s attorney, who was not authorized to accept service. Consequently, the trial court granted Crawford’s motion to quash service of the summons. Contrary to Flowers’s arguments on appeal, the trial court’s

ruling was proper and so we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Flowers filed her complaint against Crawford on March 29, 2018.3 She filed a proof of service on Crawford on June 29, 2020. According to the proof of service, a non-California registered process server left a copy of the…