The most efficient way to serve out of state summons is recurring question among attorneys. What are the rules? What classifies a proper service? In the article, “Recent NC Court Appeals Decision Loosens Rules on Service of Process on Individuals” authored by Hedrick Gardner Kincheloe & Garofalo, LLP, they note that, “In the past, the North Carolina appellate courts have required strict compliance with rules for substituted service.” However, recently on appeal, “the North Carolina Court of Appeals reversed the trial court’s decision, holding that the defendants’ affidavits stating that they each received the summons and complaint against them constituted “incontrovertible ‘other evidence’” that the summonses and complaints were “in fact received” by the defendants as required by N.C. Gen. Stat. § 1-75.10(a)(5). In so holding, the Court noted that “the greater weight of precedent supports a liberal approach to interpreting the language of the rules.”