“[T]he trial court’s order authorized substitute service at a house number on ‘Heathers Hill Drive’ in Dripping Springs, and the return stated that service was executed at the same house number but on ‘Heather Hills Drive’ in Dripping Springs. Substitute service therefore did not strictly comply with the trial court’s order. Nothing in the record demonstrates that the Spantons actually received substitute service or that Heather Hills Drive and Heathers Hill Drive are the same street. While one might reasonably presume or believe that to be true, we cannot entertain such presumptions or beliefs to uphold a default judgment based on substitute service. The face of the record in this case establishes that the substitute service did not strictly comply with the order permitting such service. As a result, the default judgment cannot stand.” Spanton v. Bellah, No. 19-0920 (Nov. 20, 2020) (emphasis modified, citation omitted).
