In re Alice D.

Respondent appealed from an order of the circuit court that denied his motion to vacate a default order terminating his parental rights after service by publication on “any and all unknown fathers.” Respondent argued that the circuit court lacked personal jurisdiction, which rendered the termination order void because the State failed to perform a diligent inquiry before attempting service by publication and the notice did not comport with statutory requirements. The appellate court reversed, finding that the circuit court lacked personal jurisdiction over the respondent because the State failed to conduct a diligent inquiry to discover his identity prior to attempting to effectuate service by publication. (McHANEY and CLARKE, concurring)