Proof of service or of posting or publication under this title may be made by, but is not limited to, the following means:
§ 684.220.Means of Making Proof of Service Or Publication
Title 9. Enforcement of Judgments · Division 1 · Chapter 4. Manner of Service of Writs, Notices, and Other Papers · Article 3. Proof of Service · Enacted 1982 · no amendments on record · Last verified July 28, 2026
In one sentenceSection 684.220 lists several non-exclusive ways to prove service, posting, or publication under this title -- summons-style proof, an affidavit describing the time, place, and manner of service, mail proof under § 1013a, posting or publication affidavits, written admission by the person served, or testimonial evidence.
Full Text of § 684.220
(b) If service is made in the same manner as a summons is served under Section 415.10 or 415.20, proof of service may be made by affidavit of the person making the service showing the time, place, and manner of service and the facts showing that the service was made in accordance with the applicable statutory provisions. The affidavit shall recite or in other manner show the name of the person to whom the papers served were delivered and, if appropriate, the title of the person or the capacity in which the person was served.
(d) Proof of posting may be made by the affidavit of the person who posted the notice, showing the time and place of posting.
(e) Proof of publication may be made by the affidavit of the publisher or printer, or the foreman or principal clerk of the publisher or printer, showing the time and place of publication.
(f) Proof of service may be made by the written admission of the person served.
(g) Proof of service however made, or of posting or publication, may be made by testimonial evidence.
Plain-English Summary
This section gathers the acceptable ways to establish that service, posting, or publication happened, without limiting proof to only these methods. If service tracked the summons manner under §§ 413.10 and following, proof can follow Article 5's summons-proof procedures (commencing with § 417.10). If service used the alternative methods in §§ 415.10 or 415.20, an affidavit describing the time, place, and manner of service — naming who received the papers and, where relevant, their title or capacity — will do.
Mail service gets its own proof method under § 1013a, and posting or publication each has an affidavit route: the person who posted, or the publisher, printer, or their principal clerk, attesting to the time and place.
Two catch-alls round out the list: a written admission from the person served works on its own, and beyond any of the specific methods, testimonial evidence can establish proof of service, posting, or publication as well.
Frequently Asked Questions
Is this list of proof-of-service methods exclusive?
No. Section 684.220 says proof may be made by, but is not limited to, the listed means.
How is proof made when service followed the summons manner?
In the manner provided in Article 5 (commencing with § 417.10) of Chapter 4 of Title 5.
What does an affidavit of service need to include for service under §§ 415.10 or 415.20?
The time, place, and manner of service, facts showing compliance with the applicable statute, and the name and, if relevant, title or capacity of the person served.
Can testimonial evidence alone establish proof of service?
Yes, subdivision (g) allows proof of service, posting, or publication to be made by testimonial evidence however the service was accomplished.
Amendment History
Added by Stats. 1982, Ch. 1364, Sec. 2. Operative July 1, 1983, by Sec. 3 of Ch. 1364.
Source & verification. Section text is reproduced verbatim from
the Deering's California Codes Annotated / vLex. Enacted by the California Legislature.
Last verified July 28, 2026.
· Official source
Also known as: proof of service methods california judgment enforcementaffidavit of service requirements