Can a Process Server Enter Private Property in California?

A process server may sometimes enter the publicly accessible portion of private property to attempt lawful service in California, but the server does not have unlimited authority to go wherever they want. A normal approach to a front door, reception desk, staffed gate, or apartment entrance may be permitted depending on the property and circumstances. The server generally cannot force entry, break a lock, climb a fence, enter a residence without permission, damage property, impersonate law enforcement, or remain after a lawful instruction to leave.

California provides specific access protections for lawful service at certain staffed gated communities and covered multifamily dwellings. California Code of Civil Procedure section 415.21 requires qualifying access for a reasonable period when the person seeking entry presents the identification and professional credentials described in the statute. California Penal Code section 602 also contains a limited vehicle-access exception for a registered process server who proceeds immediately to attempt service and leaves immediately after completing the attempt or when asked to leave.

Those rules are limited. They do not create a general right to enter a locked home, backyard, private office, restricted workplace, unstaffed property, military installation, or any other secured area. The correct approach depends on how the property is configured, whether access is staffed, what credentials the server carries, what instructions are given at the location, and which service method is legally available.

Legal disclaimer: This article provides general information about process server access and private property in California. It is not legal advice. Property access, trespass, service, and substituted service questions are fact-specific and may depend on current statutes, court decisions, local rules, document type, and a case-specific order. Reviewed September 23, 2026.

Can a Process Server Enter Private Property?

The answer is sometimes, within limits. A process server may generally attempt to reach a location that is open to ordinary visitors, such as an unobstructed front walkway, exterior front door, public lobby, reception desk, or customer entrance. The server’s lawful purpose matters, but it does not eliminate the property owner’s right to restrict access to nonpublic areas.

A process server should distinguish between an ordinary visitor route and an area that requires overcoming a physical or clearly communicated restriction. A path from the sidewalk to a front door is different from a locked gate. An open business lobby is different from an employee-only floor. A staffed community gate covered by section 415.21 is different from an unstaffed locked driveway gate.

The safest operational rule is narrow access for a legitimate service attempt, professional conduct, no force or damage, and immediate compliance when lawful control of the property requires departure.

Private Property Is Not One Single Access Zone

The phrase “private property” can describe several very different spaces. A useful service plan identifies the actual zone the process server needs to reach instead of assuming that all privately owned land is treated identically.

Publicly Accessible Areas on Private Property

Stores, office lobbies, apartment leasing offices, hotel reception areas, and medical reception desks may be privately owned but open to visitors for limited purposes. A server may usually enter through the normal public entrance and speak with staff, subject to posted hours and lawful access rules.

Ordinary Residential Approach

A typical residence may have a path, driveway, porch, or exterior door used by visitors and delivery workers. An attempt made through that ordinary approach is different from entering a locked yard or opening a secured side gate. The surrounding facts determine what is reasonably accessible.

Controlled Common Areas

Gated communities, apartment towers, condominium complexes, and staffed residential buildings may have common areas controlled by guards, concierge staff, or management. Section 415.21 addresses some of these locations directly.

Restricted Private Areas

The interior of a home, fenced backyard, locked garage, employee-only floor, warehouse production area, school classroom wing, hospital treatment area, and military installation are not ordinary visitor spaces. A process server does not gain automatic access merely by carrying legal documents.

Understanding the zone also helps the client select useful information. A unit number and callbox entry can matter more than a general street address. At a business campus, a department, suite, work shift, or public reception location may determine whether an attempt can occur without entering a restricted area.

Can a Process Server Walk Up to the Front Door?

In many ordinary residential settings, a process server may use the same unobstructed approach to the front door that a visitor, delivery worker, or member of the public would use. The server can knock, ring the bell, identify the reason for the visit in an appropriate manner, and attempt to speak with the named recipient.

This is not permission to search the property. The server should use the normal route, avoid wandering around the residence, and limit observations to what can lawfully be seen from the location of the attempt. Entering sheds, looking through covered windows, testing doors, moving barriers, or walking into secluded areas can create safety, privacy, and trespass concerns.

A sign, locked gate, fence, intercom, guard, or direct instruction may limit the ordinary approach. The server should evaluate the actual condition at the time instead of relying on a blanket statement that every front door is accessible.

What If Nobody Answers?

An unanswered knock does not usually authorize leaving the packet unattended. Personal service requires delivery to the named person, and substituted service requires compliance with the applicable statute. Review our detailed guide on whether a process server can leave papers at the door in California.

The server should document the attempt, including the exact time, visible address, access conditions, vehicles or occupancy indicators, and whether anyone responded. Observations should be factual. A parked car or a light inside does not prove that the recipient is present.

What a Process Server Cannot Do on Private Property

A lawful service objective does not authorize force, damage, intimidation, or deception about official authority. Professional servers should avoid any conduct that creates a separate legal problem or undermines the credibility of the Proof of Service.

A process server should not:

• Break or manipulate a lock
• Climb a secured fence or wall
• Force open a gate, door, window, or garage
• Enter the interior of a residence without permission
• Follow a resident through a secured entrance without lawful authorization
• Damage landscaping, signs, doors, vehicles, or other property
• Claim to be a police officer, sheriff, court officer, or government employee when that is untrue
• Use threats or physical force to make someone accept papers
• Block a person or vehicle from leaving
• Remain after a person with lawful control of the property directs the server to leave
• Use private information or access credentials obtained unlawfully
• Photograph or record in a manner prohibited by law or a court order

The correct response to a barrier is usually documentation and strategy, not escalation. A denied attempt may lead to a different time, another location, workplace service, address research, substituted service, or a request for court-authorized relief.

California Gated Community Access Under CCP 415.21

California Code of Civil Procedure section 415.21 creates a specific access rule for gated communities and covered multifamily dwellings that are staffed at the time of the attempt by a guard or other security personnel assigned to control access.

Under the statute, access must be granted for a reasonable period for the sole purpose of performing lawful service of process or serving a subpoena when the person seeking access displays a current driver’s license or other identification and one of the professional credentials listed in the statute.

Qualifying credentials include:

• A badge or confirmation showing that the person acts for a county sheriff or marshal
• Confirmation of specified government investigator status
• Evidence of current registration as a California process server
• Evidence of current licensure as a California private investigator

This access is limited by purpose and time. It is not permission to conduct unrelated investigation, wait indefinitely, roam through the community, or enter an individual home. The server should proceed to the service location, make the lawful attempt, and leave when the task is completed or access is otherwise lawfully ended.

What Is a Covered Multifamily Dwelling?

For section 415.21, a covered multifamily dwelling includes an apartment building with three or more dwelling units and a condominium with four or more dwelling units, including certain timeshare properties that are not treated as public accommodations or transient lodging.

The staffing condition is critical. The section applies only when the gated community or covered multifamily dwelling is staffed at the time by a guard or other security personnel assigned to control access. It does not instruct a process server to defeat an automated gate at an unstaffed property.

What Should the Server Present?

A registered process server should be prepared to show current government identification and evidence of current process server registration. The server should state the lawful purpose calmly and provide only the information required for access. Field notes should record the name or description of security personnel, credentials shown, time of the request, and response.

What If the Guard Still Refuses Entry?

The server should not force the gate or create a confrontation. The denial should be documented accurately and reported to the client. Useful details include whether the location was staffed, who controlled access, what credentials were shown, what the guard said, whether management was contacted, and whether the recipient was confirmed as a resident.

Depending on the documents and attempt history, the next step might involve another properly documented request, communication with management, a workplace attempt, or legal review of an alternative service method. Difficult access combined with evasive behavior may justify a more strategic difficult or evasive respondent service plan.

Apartments, Condominiums, and Secured Buildings

Apartment service can involve several layers of access: the exterior complex gate, building lobby, elevator, secured floor, hallway, and individual unit door. Reaching one layer does not automatically authorize entry through every later barrier.

At a staffed property covered by section 415.21, a qualifying server can request reasonable access using the required identification and credentials. At an unstaffed building, the server may use the callbox, contact management during business hours, attempt another lawful entrance, or report that access was unavailable.

The server should not:

• Tailgate a resident through a locked door without lawful authorization
• Misrepresent the purpose of the visit to obtain a key or access card
• Use a gate code that the client was not legally entitled to provide
• Force an elevator to a restricted floor
• Enter a tenant’s unit without an invitation
• Leave papers in a shared lobby and describe the event as personal service

A leasing office employee, concierge, or guard is not automatically authorized to accept personal service for an individual resident. Whether another method may be available depends on the documents, prior diligence, recipient’s relationship to the location, and statutory requirements.

Registered Process Servers and Vehicle Access Under Penal Code 602

California Penal Code section 602 lists several forms of trespass. Subdivision (n) addresses driving a vehicle onto private property known not to be open to the general public without consent. The subdivision contains a limited exception for a person described in Business and Professions Code section 22350 who is making lawful service of process.

The exception is conditional. After exiting the vehicle, the registered process server must proceed immediately to attempt service and must leave immediately after completing service or when the owner, the owner’s agent, or the person in lawful possession asks the server to leave.

This is not an all-purpose parking privilege. It does not authorize waiting for hours, exploring the property, blocking access, remaining after a request to leave, or using the property for surveillance unrelated to the immediate attempt. It also does not eliminate separate access restrictions at secured facilities.

The distinction between a brief attempt and a stakeout matters. If waiting near a difficult address is appropriate, the server should remain in a place where the server is legally permitted to be, such as a lawful public parking location. A client considering extended surveillance should provide the address, schedule information, vehicle description, and deadline so the provider can evaluate a lawful plan.

What Happens If a Process Server Is Asked to Leave?

A process server should normally comply promptly with a clear instruction from the property owner, lawful occupant, manager, or authorized agent to leave. Arguing about the case or remaining on the property can create unnecessary risk and may change an otherwise legitimate attempt into a trespass dispute.

Leaving does not mean the lawsuit ends or the assignment fails permanently. The server can record:

• The exact location and time
• Who directed the server to leave
• That person’s apparent authority or role
• Whether credentials were shown
• Whether the intended recipient was seen or identified
• Any statements about residency, employment, or availability
• Whether a gate, guard, lobby, or locked entrance prevented contact
• Whether documents were delivered before the instruction

The report should distinguish facts from conclusions. “Security guard denied access after registration card was shown” is more useful than “they are hiding the defendant.” Accurate notes help the client decide whether to try again, change locations, or ask counsel about another permitted method.

Can a Process Server Enter Someone’s Home?

A process server does not have a general right to enter the interior of a private residence. The resident may voluntarily invite the server inside, but the server should not push past a person, cross a threshold without permission, wedge a closing door, or enter because the door happens to be unlocked.

Personal service can often be completed at the doorway. The recipient does not have to invite the server inside. If identity is established and the recipient refuses to accept the documents, the server may be able to state the nature of the papers and place them near the recipient under circumstances recognized as effective delivery. The server should document the encounter carefully.

Entering with consent still does not authorize a search of the home. If the invitation is withdrawn, the server should leave. Safety should take priority if the encounter becomes hostile, a weapon is visible, an animal presents a risk, or another immediate hazard develops.

Can a Process Server Enter a Backyard, Garage, or Side Yard?

Backyards, enclosed side yards, garages, and other areas outside the ordinary visitor route create greater access risk. There is no universal California rule that makes every unlocked gate an invitation to enter. Fences, gate placement, signs, locks, landscaping, and the property’s layout may show that an area is private and not intended for visitors.

A professional server should not climb a fence, unlock a gate, manipulate a latch intended to secure a private area, enter a closed garage, or walk through an occupied home’s side or rear entrance merely because the front door was unanswered.

If the intended recipient is visible in an accessible area, the server may be able to communicate from a lawful location and ask the person to approach. The server should avoid shouting details about the lawsuit across a neighborhood or creating a public confrontation.

What About an Open Garage?

An open garage does not automatically become a public entrance. The server may call out from the normal approach path but should not walk into the garage without permission. If the recipient comes to the driveway or doorway, personal service may be completed there if identity and delivery requirements are satisfied.

Private Workplaces and Restricted Facilities

A person may generally be served at work if the process server can lawfully reach and identify the recipient. That does not create unrestricted access to private offices, warehouses, hospitals, schools, secured campuses, construction sites, airports, military facilities, or employee-only areas.

The server should begin at the public-facing entrance, comply with check-in and safety procedures, and ask reception or security to contact the employee. If the employee comes to the lobby, service may be completed without entering a restricted area.

Leaving papers with reception is not automatically personal service on the employee. Substituted service at a usual place of business has separate diligence, recipient, mailing, and completion requirements. Read our full guide to serving someone at work in California.

Some locations require special planning:

• Hospitals: patient privacy, treatment areas, infection control, and visitor limits apply.
• Schools: campus security and student safety procedures apply.
• Military facilities: federal access controls and identification requirements apply.
• Construction and industrial sites: safety training, protective equipment, and restricted zones may apply.
• Hotels: staff may protect guest privacy and decline to provide a room number.
• Government buildings: screening, hours, and secure-area rules apply.

If access is denied, the process server should leave when directed and document the attempt. The recipient may be approached at another lawful location or time.

What If the Recipient Refuses the Papers at the Door?

A recipient generally cannot defeat personal service simply by refusing to take the packet after being reliably identified. If the server clearly informs the person that legal documents are being delivered, service may sometimes be completed by placing the papers near the recipient in a manner reasonably calculated to provide possession and notice.

This does not mean papers can be thrown onto an empty porch after someone closes the door. The distinction depends on the recipient being present, identity being established, communication occurring, and the documents being placed in reasonable proximity.

The server should document:

• How the recipient was identified
• What the server said
• How the recipient refused
• Where the papers were placed
• Whether the recipient saw or acknowledged them
• Whether the door, gate, or threshold affected delivery
• The names or descriptions of any witnesses

A person who refuses service may still be validly served, while someone who was never identified and was not present may not be. Avoidance and refusal require different analysis. For related strategy, see what happens when someone avoids a process server in California.

What Happens After Access Is Denied?

A denied entrance is information, not permission to escalate. The next step should be based on the documents, deadline, address reliability, previous attempt history, and the specific reason contact failed.

Try a Better Time

If access depends on staffed hours, recipient availability, or management, another attempt during a different lawful window may solve the problem. Attempt timing should reflect the recipient’s probable schedule rather than repeating the same unsuccessful hour.

Use Another Lawful Location

A workplace, public meeting place, business appointment, or another verified address may offer lawful access. The service method must still be authorized for the documents.

Verify the Address

Access problems can hide a more basic issue: the recipient may no longer live there. If occupancy is uncertain, address research may be more useful than repeated gate attempts. Our skip tracing and address research service can help evaluate alternate residential and workplace leads.

Build Useful Diligence

When substituted service or court-authorized relief may later be requested, the quality of each attempt matters. Vary timing, record access facts, and preserve statements from guards or occupants. There is no universal attempt count for every assignment. Review our guide to process serving attempts in California.

Review Another Authorized Method

Depending on the case, the client or attorney may consider substituted service, mail with acknowledgment, publication, posting, electronic service, or another court-ordered method. A process server should not choose a legally disputed alternative without instructions and authority.

Can Papers Be Left With a Gate Guard?

Not automatically. A guard’s control of the entrance does not convert every delivery into valid substituted service. The available method depends on the documents, reasonable diligence, the guard’s relationship to the property and recipient, required mailing, and applicable case law.

In Bein v. Brechtel-Jochim Group, Inc., a California Court of Appeal addressed substituted service involving a guard who controlled access to a gated residential community after repeated personal service efforts. The decision is often cited in discussions of gate guard service, but it should not be reduced to a blanket rule that any guard can receive any papers.

For a civil summons under Code of Civil Procedure section 415.20, substituted service generally requires reasonable diligence before personal delivery is abandoned, delivery at a qualifying location to an appropriate person, informing that person of the nature of the papers, and mailing another copy as required. The exact statutory text in effect on the service date should be reviewed because California service statutes can be amended.

A Proof of Service should accurately state that substituted service was used. It should not report personal service on the named recipient when the documents were delivered to security.

How Private Property Attempts Should Be Documented

Private property service often produces later questions about access, identity, refusal, and delivery. Detailed contemporaneous notes help the client, attorney, and court understand what occurred.

A strong attempt record may include:

• Date and exact time
• Complete address, unit, suite, or building
• Whether the location was residential, commercial, gated, or multifamily
• Whether the gate or building was staffed
• Names or descriptions of guards, managers, occupants, or reception staff
• Identification and credentials shown
• Access requested and the response received
• Whether the server was directed to leave and when the server departed
• Callbox, intercom, lobby, elevator, or parking restrictions
• Statements about residency, employment, schedule, or availability
• How the intended recipient was identified
• Exact delivery or refusal facts
• Where papers were placed, if delivery occurred
• Lawfully observed occupancy indicators
• Recommended next step

Photographs may help document an address, gate, or access barrier when they are lawfully taken and do not expose confidential documents or private information. The provider should follow applicable privacy rules, client instructions, and property restrictions.

After successful service, the server prepares the applicable Proof of Service. A digital copy may be returned to the client, while filing responsibility should be confirmed separately. Learn more about what happens after a process server serves the papers.

Private Property Service in San Diego County

San Diego County contains a wide range of property types, and each creates a different access plan. A downtown high-rise may have a concierge, controlled elevators, parking restrictions, and a resident directory. A North County gated community may use a staffed entrance during limited hours. An East County property may have a long private driveway, unstaffed gate, animals, or limited cellular service.

Common San Diego access conditions include:

• Secured apartment and condominium buildings in Downtown San Diego
• Gated communities in North County and inland neighborhoods
• Military housing and federal facilities with separate access controls
• Large medical campuses with patient privacy restrictions
• Biotechnology, defense, and corporate campuses with security desks
• University and school properties with visitor screening
• Hotels and short-term rental properties where occupancy may be temporary
• Rural and semi-rural properties with long driveways, fences, and animals

Clients should provide the unit or suite, callbox name, gate instructions lawfully available to them, recipient photograph, known vehicle, schedule, prior attempt reports, and deadline. Better intake reduces unnecessary visits and helps the server choose a lawful contact point.

If timing is critical, same-day and rush process service in San Diego can prioritize review and dispatch. Rush service accelerates the attempt schedule but does not authorize entry into restricted property or guarantee that the recipient will be accessible.

For routine service, see our complete San Diego process serving services. The assignment can be reviewed for document type, access conditions, attempt timing, and Proof of Service requirements before dispatch.

Private Property Service Examples

Example 1: Unobstructed Front Walkway

The residence has no fence, gate, or sign restricting the normal walkway. The process server walks to the front door, knocks, and speaks with the named recipient. The recipient accepts the packet. The server leaves promptly and records personal service.

Example 2: Nobody Answers the Door

The process server uses the ordinary walkway and receives no response. The server records the attempt and leaves. The packet is not left on the porch because no authorized door-posting method applies.

Example 3: Staffed Gated Community

A registered process server arrives while the community entrance is staffed by security. The server displays current identification and registration evidence and requests reasonable access under section 415.21 for lawful service. The guard grants entry. The server proceeds to the address, makes the attempt, and exits without delay.

Example 4: Unstaffed Locked Gate

The process server reaches a locked automated gate with no guard present. The server does not force the gate or follow another vehicle through. The access condition is documented, and the client is asked for lawful callbox information, another contact point, or an alternate address.

Example 5: Security Refuses Access

The server presents qualifying credentials, but the guard refuses entry. The server remains professional, records the guard’s name or description and statements, reports the denial, and leaves. Counsel can review whether another attempt or method is appropriate.

Example 6: Recipient Refuses at the Threshold

The recipient opens the door, confirms identity, and refuses to touch the packet. The server states that the papers are legal documents being served, places them at the recipient’s feet in reasonable proximity, leaves safely, and documents every detail of the refusal.

Example 7: Open Garage

The garage door is open, but nobody is in the driveway. The process server calls out from the normal visitor route and does not enter the garage. When there is no response, the server leaves and records an unsuccessful attempt.

Example 8: Workplace Security Desk

A security officer prevents entry beyond the lobby but agrees to call the employee. The employee comes to the lobby and is personally served. The server never enters the restricted office area.

Example 9: Apartment Concierge

The concierge confirms that the resident lives in the building but says building policy prohibits visitor access. The server presents the credentials required by section 415.21 and requests lawful access. The outcome, including any continued denial, is documented precisely.

Example 10: Incorrect Address

A current occupant states that the recipient moved several months ago. Repeated property-access attempts are unlikely to solve an address problem. The client provides prior addresses and employer information for research before another field attempt is ordered.

Client Checklist for a Secured or Private Address

Before sending a process server to a gated or restricted property, provide:

• The complete service packet
• The exact service deadline and hearing date
• The recipient’s full legal name and known aliases
• The complete address, unit, suite, building, or department
• A current photograph or detailed physical description
• Known vehicle information
• Work schedule or likely availability
• Callbox or directory name
• Lawfully available visitor or management instructions
• The name and hours of the gate, lobby, or security office
• Previous attempt reports
• Alternate residence or workplace information
• Any known safety concern, animal, weapon, or hostile-contact history
• Whether substituted service is authorized if personal service fails
• Any court order governing the manner of service

Do not direct a process server to break access rules, conceal identity, use force, or enter a residence without permission. If the deadline is close, disclose it at intake so the provider can explain what attempt windows remain. You can also compare scheduling and additional services in our guide to process server costs in San Diego.

Frequently Asked Questions

Can a process server enter private property in California?

Sometimes, for a limited lawful attempt. A server may often use an ordinary visitor route or public-facing entrance. Specific statutes provide qualifying access to certain staffed gated communities and multifamily dwellings. The server does not have unlimited access to locked, private, or restricted areas.

Can a process server walk onto my porch?

A server may often approach an unobstructed front porch by the normal visitor route to knock or ring the bell. Barriers, signs, gates, direct instructions, and the property’s configuration may limit access.

Can a process server open a gate?

There is no universal answer for every unlocked gate. A normal front entry gate can differ from a secured side or backyard gate. A server should not break a lock, manipulate a secured barrier, damage property, or enter an area clearly not open to visitors.

Can a process server enter a locked gated community?

California Code of Civil Procedure section 415.21 requires reasonable access at qualifying staffed gated communities and covered multifamily dwellings when the server displays the required identification and professional credentials. The statute does not authorize forcing an unstaffed gate.

Does an apartment manager have to let a process server inside?

Section 415.21 may require qualifying access when the property is a covered multifamily dwelling staffed by security personnel controlling access at the time. The exact facts, staffing, credentials, and statutory definitions matter.

Can a process server enter my house?

Not without permission or another lawful authority. The server can usually complete service at the doorway and should not push past a resident or enter merely because a door is open.

Can a process server enter a backyard?

A backyard or enclosed side yard is more private than an ordinary front-door approach. The server should not climb fences, defeat locks, or enter areas clearly not intended for visitors. Property layout and access restrictions matter.

Can a process server enter an open garage?

An open garage is not automatically a public entrance. The server may communicate from a lawful approach but should not walk into the garage without permission.

Can a process server remain after being asked to leave?

Generally, the server should leave promptly when directed by a person with lawful control of the property. The instruction and surrounding facts should be documented for the client.

Can a process server park on private property?

Penal Code section 602(n) contains a limited exception for a registered process server making lawful service, provided the server proceeds immediately to the attempt after exiting the vehicle and leaves immediately after service or when asked to leave. It is not permission for indefinite parking or surveillance.

Can security accept papers for a resident?

Not automatically. Delivery to a guard may qualify as substituted service only in appropriate circumstances when the document permits it and all diligence, recipient, notice, mailing, and completion requirements are satisfied.

Can a process server pretend to be someone else to gain entry?

A process server should not impersonate law enforcement, a government official, a delivery worker, or another person to overcome restricted access. Misrepresentation can create legal, safety, and evidentiary problems.

Can papers be left at the gate?

Not merely because entry was denied. Leaving papers unattended at a gate is not automatically personal or substituted service. A statute or court order must authorize the actual method used.

What if the recipient is visible behind the gate?

The server may communicate from a lawful position and attempt to establish identity. Whether delivery can be completed depends on distance, communication, placement of the documents, safety, and the service rule. The server should not climb or force the gate.

Does refusing property access stop the lawsuit?

No. Denied access may lead to another attempt, another location, substituted service, or a court request for an alternative method. It does not make the underlying case disappear.

What should I do if I believe a process server trespassed?

Preserve video, photographs, dates, messages, witness information, and the documents. Avoid confrontation. A California attorney can assess the property facts, service validity, and any appropriate court or law enforcement procedure.

Official and Primary Legal Sources

• California Code of Civil Procedure section 415.21, access to qualifying staffed gated communities and covered multifamily dwellings
• California Penal Code section 602, trespass provisions and the limited registered-process-server vehicle exception
• California Business and Professions Code section 22350, process server registration
• California Code of Civil Procedure section 415.10, personal service of summons
• California Code of Civil Procedure section 415.20, substituted service
• Bein v. Brechtel-Jochim Group, Inc. (1992) 6 Cal.App.4th 1387, California Court of Appeal decision discussing gate guard substituted service
• California Courts Self-Help Guide to Serving Court Papers