After a motor-vehicle collision, Marion James sued Robert Henderson for personal injuries. Attempts to serve Henderson at the address listed in the accident report failed because the property was vacant. James’s counsel then obtained an order for service by publication, stating that Henderson had apparently left the county and state and that his location was unknown. Henderson was never personally served, and his insurer moved to dismiss for lack of personal jurisdiction. The trial court denied the motion. The Court of Appeals reversed. It held that service by publication was insufficient because the record did not establish that Henderson resided in the county, that he was within the court’s jurisdiction, or that he had actual knowledge of the lawsuit. Publication may provide notice only after reasonable diligence and cannot substitute for personal jurisdiction on these facts. The decision protects the constitutional fairness requirement in service by publication and rejects the possibility of entering a personal money judgment against a defendant who was not adequately notified.