In Fidelity & Guaranty Insurance Co. v. Drewery Construction Co., 186 S.W.3d 571 (Tex. 2006), the court discussed the distinction between restricted appeals and appeals from a denial of a motion for new trial in the context of default judgments. The court explained that because of the differences in the two procedures, "cases concerning one do not necessarily apply to the other." Fidelity, 186 S.W.2d at 573. The court, however, did not dispense with the requirement of proper service in default judgment cases and, in fact, continued to recognize well-settled law that receiving papers or notice through a procedure not authorized by law is treated the same as never receiving them. Fidelity, 186 S.W.3d at 574 n.1.