Geraldine Akpan sued members of the Shuler family, alleging that they conspired to defraud an estate of assets and property. After the defendants failed to answer following service by publication, the trial court entered a default judgment. The Court of Appeals of Georgia vacated and remanded. It held that service by publication requires reasonable diligence to locate the defendant and that the record did not establish the constitutionally required effort. Because defective service deprived the trial court of personal jurisdiction, the default judgment could not stand.