Obtaining Jurisdiction of a Person After the Right or Cause of Action Already Existed
In Ogdon v. Gianakos, 415 Ill. 591, 114 N.E.2d 686 (1953), defendant was served with process in conformity with the laws of Illinois in force at the time of service.
At that time, the law permitted substituted service on the Secretary of State for a former resident who no longer lived in Illinois.
However, when the cause of action arose, the statute did not allow substitute service.
The Court concluded that the statute in question was merely a step in obtaining jurisdiction of the person after the right or cause of action existed.
Thus, it was part of the law of procedure, not substance and applied retroactively. Ogdon, 415 Ill. 591, 114 N.E.2d 686.