Bonita Packing Co. v. O'Sullivan

In Bonita Packing Co. v. O'Sullivan (C.D.Cal. 1995) 165 F.R.D. 610, the federal district court construed the italicized language to encompass private mailboxes as well as United States Postal Service boxes. (Bonita, supra, 165 F.R.D. at p. 614.) The court stated in Bonita: "The Legislature, in specifically excluding United States Postal Service post office boxes from coming within the phrase 'usual mailing address,' has shown its intention to preclude substituted service at postal boxes. In the Court's opinion, a private post office box is akin to a United States Postal Service post office box; and unlike a 'dwelling house,' 'place of abode' or 'place of business.'" (Ibid.) Further, the court in Bonita relied on the fact a better method of service was easily available to the plaintiffs. (Ibid.)