delivered the opinion of the court:
There are two issues in this appeal. The threshold issue is whether an order vacating a default judgment on the ground that it is void for lack of proper service of process is an appealable order. The second issue is whether service of process was proper in this case. The appellate court held that the order vacating the default judgment was a final, appealable order. The appellate court also found that service of process was proper. 308 Ill. App. 3d 137. For reasons that follow, we affirm the judgment of the appellate court, which remanded the cause to the trial court for further proceedings.
BACKGROUND
On January 26, 1988, Sam Sarkissian (Sarkissian), as parent and guardian of Sonya Sarkissian, a minor, filed a personal injury action against the Chicago board of education (the Board) in the circuit court of Cook County. The complaint alleged that, on September 24, 1985, Sonya Sarkissian suffered an epileptic seizure while attending Armstrong public school. It was further alleged that the Board and its agents, although aware that Sonya suffered from epilepsy, failed to promptly summon or render appropriate medical assistance when the seizure occurred and, as a result, Sonya sustained serious and permanent injuries.1
On February 1, 1988, a deputy sheriff delivered a copy of the complaint and summons, addressed to “the Chicago Board of Education,” to the Board’s corporate offices at 1819 West Pershing in Chicago. The summons and complaint were given to, and accepted by, the receptionist of the Board’s law department. The Board’s appellate counsel conceded during oral argument before this court that the complaint and summons were received by the receptionist and that she transmitted the documents to a Board attorney. The Board attorney, in turn, forwarded the papers to the Martin Boyer Company, which served at that time as the Board’s risk management company. It was the responsibility of the Martin Boyer Company to acquire outside counsel to defend the Board in personal injury matters. However, according to appellate counsel, the case “slipped through the cracks.” No one filed an appearance on behalf of the Board and the complaint was never answered.
Notice that plaintiff would be seeking a default judgment was sent to the Board on July 28, 1988, via certified mail. The Board’s time stamp appears on the certified mail receipt, showing that the Board received this notice on July 29, 1988. Still no action was taken by the Board. On August 29, 1988, an order of default was entered and, after prove-up on April 17, 1990, the trial court entered a $10 million default judgment in plaintiffs favor and against the Board.
The record further reveals that on August 25, 1997, plaintiff petitioned to revive the default judgment. See 735 ILCS 5/12 — 108(a) (West 2000) (a judgment that is more than seven years old must be revived prior to enforcement). The Board received notice of the plaintiffs revival petition on September 2, 1997. Notice of the revival petition was served on the Board in exactly the same manner as when the Board had been served with notice of plaintiffs complaint — by leaving a copy of the petition and summons with the receptionist at the law department. On October 1, 1997, the Board filed a general appearance. Then, on November 5, 1997, the Board filed a motion to vacate the default judgment as void, claiming that under section 2 — 211 of the Code of Civil Procedure, a summons issued to the Board must be served on “the president or clerk or other officer corresponding thereto.” 735 ILCS 5/2 — 211 (West 2000). According to the Board, service did not conform with section 2 — 211 because the summons was not addressed to any specific individual and was left with a receptionist in the Board’s legal department, who was not designated by statute to receive service of process. Thus, the Board contended that the trial court never acquired personal jurisdiction over it and, as a result, the default judgment entered was void.
Plaintiff denied that process served on the Board did not satisfy the requirements of section 2 — 211. Plaintiff contended that the Board’s attorney was an “officer” within the meaning of section 2 — 211 and that the attorney delegated authority to the receptionist to accept service of summonses. In support, plaintiff submitted evidence that the Board’s long-standing custom, practice, and procedure was to have the receptionist of the Board’s legal department accept service of summons on behalf of the Board. Plaintiff submitted the deposition testimony of 12 witnesses, including Frank Gardner, who had been the Board’s president between 1987 and 1989; Patricia Whitten, who had been chief counsel for the Board from 1982 until 1990; and receptionists Nancy Faulk and Yolanda Chavez. The deposition testimony established that, for many years, the receptionist for the law department was a person authorized and designated to accept summonses for the Board. No one could recall a time when service of summonses on the Board via the receptionist of the law department had ever been contested as being improper.
The Board, however, contended that the receptionist of the law department accepted service of summonses as an “accommodation” to the public and that strict compliance with the statute could be demanded by the Board. The Board contended that its failure to contest service in other cases meant only that the Board had waived proper service in those instances.
The trial court ruled in the Board’s favor, finding that the summons served on the Board in this case was not in conformity with section 2 — 211. The trial court vacated the default judgment, but authorized the issuance of an alias summons, addressed to the Board’s president. On July 28, 1998, the alias summons — like the original summons — was accepted by a receptionist in the Board’s law department. The Board has not filed an appearance in response to the alias summons.
Plaintiff appealed the trial court’s order vacating the default judgment. The Board, however, moved to dismiss the appeal, arguing that appellate jurisdiction was lacking. The Board contended that the order vacating the default judgment was not final and, therefore, not appealable. The motion to dismiss was taken with the case.
The appellate court denied the motion to dismiss, finding that the order was a final order, appealable pursuant to Supreme Court Rule 303. After rejecting the Board’s jurisdictional challenge, the appellate court ruled on the merits, finding that valid service on the Board had been effectuated in compliance with section 2 — 211. The appellate court reversed the order vacating the default judgment and remanded the cause for further proceedings. 308 Ill. App. 3d 137.
We allowed the Board’s petition for leave to appeal. 177 Ill. 2d R. 315(a). In addition, we granted leave to the Illinois Association of School Boards, the Illinois Association of Park Districts, the Illinois Library Association, and the Illinois Governmental Association of Pools to submit a joint brief as amici curiae in support of the Board. 155 Ill. 2d R. 345.
On January 29, 2001, this court filed an opinion, with two justices dissenting. The majority, exercising this court’s supervisory authority, reversed the judgment of the appellate court and affirmed the judgment of the circuit court. Thereafter, on July 6, 2001, plaintiffs petition for rehearing was granted.
Now, having had the benefit of additional argument, we affirm the judgment of the appellate court, which remanded the cause to the circuit court for further proceedings.
ANALYSIS
Jurisdiction
It is necessary, at the outset, to identify the basis for this court’s exercise of jurisdiction over this appeal. The Board argues here, as it did before the appellate court, that a court of review has no jurisdiction over a trial court’s order vacating a default judgment on grounds that service of process was defective. Such orders, the Board claims, are not final orders and, thus, not appeal-able under our supreme court rules. Although the Board acknowledges that there is a split of authority on this issue, the Board cites to cases which support its position. See Nelson v. United Airlines, Inc., 243 Ill. App. 3d 795 (1993); Stankowicz v. Gonzalez, 103 Ill. App. 3d 828 (1981); Alexander v. Burke, 6 Ill. App. 3d 919 (1972); Mabion v. Olds, 84 Ill. App. 2d 291 (1967).
Plaintiff disputes the Board’s claim that the order here is not final. Citing Cavanaugh v. Lansing Municipal Airport, 288 Ill. App. 3d 239 (1997), and DiNardo v. Lamela, 183 Ill. App. 3d 1098 (1989), plaintiff argues, and the appellate court below held, that an order vacating a default judgment for lack of proper service is, in essence, an order quashing service of process. Relying on this court’s opinion in Brauer Machine & Supply Co. v. Parkhill Truck Co., 383 Ill. 569 (1943), for the proposition that orders quashing service of process are final orders, plaintiff contends, “where the judgment is vacated due to improper service *** an appeal may be had from this order.” DiNardo, 183 Ill. App. 3d at 1103.
While we agree with the appellate court that appellate jurisdiction exists in this case, we do so for different reasons. Section 2 — 1401 of the Code of Civil Procedure (735 ILCS 5/2 — 1401 (West 2000)) authorizes a party to seek relief from a final judgment, such as a default judgment, when brought more than 30 days after judgment has been entered. See Smith v. Airoom, Inc., 114 Ill. 2d 209 (1986); 735 ILCS 5/2 — 1401(a) (West 2000). The filing of a section 2 — 1401 petition is considered a new proceeding, not a continuation of the old one. 735 ILCS 5/2 — 1401(b) (West 2000); Mitchell v. Fiat-Allis, Inc., 158 Ill. 2d 143, 149 (1994). Thus, a circuit court’s ruling on such a petition is deemed a final order and provision has been made for immediate review of these orders in Supreme Court Rule 304(b)(3), which states that appeal may be taken from “a judgment or order granting or denying any of the relief prayed in a petition under section 2 — 1401 of the Code of Civil Procedure” (155 Ill. 2d R. 304(b)(3)).
There are sound policy reasons for allowing review of orders granting relief from final judgments. Once a final judgment has been rendered, setting it aside is a matter of considerable significance. Moreover, it is impractical to subject parties to the time and expense of trial before it is known whether the circuit court’s decision to set aside an existing final judgment is proper.
In the present case, the Board filed a motion seeking relief from a final judgment, brought more than 30 days from the judgment’s entry. Regardless of the label which the Board gave to its motion, the motion was, in substance, a section 2 — 1401 motion. See Barnes v. Southern Ry. Co., 116 Ill. 2d 236 (1987) (the caption of a motion is not controlling; the character of the pleading is determined from its content, not its label); Padilla v. Vazquez, 223 Ill. App. 3d 1018, (1991) (when analyzing a pleading, a court will look to the content of the pleading rather than its label). The order which plaintiff now seeks to have reviewed is the circuit court’s order granting the Board’s motion to vacate the final default judgment. In light of the foregoing, one might expect that, in the case at bar, there would be no question regarding appellate jurisdiction. However, the problem here stems from the fact that the Board’s motion was brought more than seven years after the default judgment was entered, on grounds that the judgment was void for lack of proper service. As a general rule, petitions brought pursuant to section 2 — 1401, to be legally sufficient, must be filed within two years of the order or judgment, the petitioner must allege a meritorious defense to the original action, and the petitioner must show that the petition was brought with due diligence. 735 ILCS 5/2 — 1401(b), (c) (West 2000); Airoom, 114 Ill. 2d at 221-22.
It is undisputed that, as a general matter, the Board had the right to challenge the default judgment on voidness grounds in the circuit court, for it is well settled that “[a] judgment, order or decree entered by a court which lacks jurisdiction of the parties or of the subject matter, or which lacks the inherent power to make or enter the particular order involved, is void, and may be attacked at any time or in any court, either directly or collaterally.” Barnard v. Michael, 392 Ill. 130, 135 (1945). The controversy, however, is over the proper labeling of the motion. The appellate court in Mabion, Alexander, Stankowicz and Nelson did not recognize petitions seeking to vacate void judgments as petitions for relief from judgment brought pursuant to section 2 — 1401 of the Code of Civil Procedure (formerly section 72 of the Civil Practice Act). These courts interpreted the language contained in paragraph (f) of section 2 — 1401 (formerly section 72(6) of the Civil Practice Act) as excluding motions brought on voidness grounds from the purview of section 2 — 1401.
Not all appellate court panels have reached the same conclusion. In Slates v. International House of Pancakes, Inc., 90 Ill. App. 3d 716, 723 (1980), the court said:
“We do not read this section, as some courts have, as removing motions attacking a void judgment from the ambit of section 72. [Citation.] Rather, we read section 72(6) as a clarification that section 72 provides a parallel mode for contesting void judgments.”
Until recently, this court had not spoken on the issue of whether motions attacking void judgments could be recognized as section 2 — 1401 petitions. However, in People v. Harvey, 196 Ill. 2d 444, 454 (2001), four members of this court held that a motion to vacate a void judgment is properly designated a petition for relief from judgment under section 2 — 1401 of the Code of Civil Procedure (735 ILCS 5/2 — 1401 (West 2000)). Pursuant to Harvey, paragraph (f) of section 2 — 1401, which provides, “Nothing contained in this Section affects any existing right to relief from a void order or judgment, or to employ any existing method to procure that relief,” does not exclude, but merely differentiates, post-judgment petitions brought on voidness grounds from general section 2 — 1401 petitions. See 735 ILCS 5/2— 1401(f) (West 2000). Under paragraph (f), the general rules pertaining to section 2 — 1401 petitions — that they must be filed within two years of the order or judgment, that the petitioner must allege a meritorious defense to the original action, and that the petitioner must show that the petition was brought with due diligence — do not apply. Petitions brought on voidness grounds need not be brought within the two-year time limitation. Further, the allegation that the judgment or order is void substitutes for and negates the need to allege a meritorious defense and due diligence. People v. Harvey, 196 Ill. 2d 444, 452 (2001) (McMorrow, J., specially concurring, joined by Freeman, J.).
We note, also, that paragraph (a) of section 2 — 1401 expressly abolishes all other common law means of attacking void judgments. It provides in pertinent part:
“Writs of error coram nobis and coram vobis, bills of review and bills in the nature of bills of review are abolished. All relief heretofore obtainable and the grounds for such relief heretofore available, whether by any of the foregoing remedies or otherwise, shall be available in every case, by proceedings hereunder, regardless of the nature of the order or judgment from which relief is sought or of the proceedings in which it was entered.” (Emphasis added.) 735 ILCS 5/2 — 1401(a) (West 2000).
Moreover, nowhere else in the Code of Civil Procedure does the legislature make provision for the filing of a motion to challenge a judgment on voidness grounds.
Harvey recognized that petitions seeking relief from void judgments are section 2 — 1401 petitions. That being the case, it follows that any order granting or denying such relief is a final ruling, appealable pursuant to Supreme Court Rule 304(b)(3) (155 Ill. 2d R. 304(b)(3)).
In the present case, the Board petitioned for relief from a default judgment which had been entered more than seven years earlier. The Board alleged that the default judgment was void because the trial court lacked personal jurisdiction due to defective service of process. We conclude, pursuant to Harvey, that the Board’s petition was one which sought post-judgment relief under section 2 — 1401 and could validly be brought outside the two-year limitations period. Also, there was no need for the Board to establish that it had acted with due diligence or to allege that a meritorious defense existed. Because the Board’s motion was a valid section 2 — 1401 motion, the trial court’s order granting the Board’s motion to vacate is, pursuant to Supreme Court Rule 304(b)(3), a final, appealable order.
Justice Thomas maintains in his dissent that a motion to vacate a judgment as void is not the same as a section 2 — 1401 petition. 201 Ill. 2d at 133 (Thomas, J., dissenting, joined by Fitzgerald, J.). Accordingly, in the present case, Justice Thomas does not recognize the Board’s motion to vacate as a petition brought under section 2 — 1401. Instead, he distills the Board’s motion into a motion to quash service of process. Justice Thomas then reads Brauer Machine & Supply Co. v. Parkhill Truck Co., 383 Ill. 569 (1943), as standing for the proposition that the finality of an order quashing service of process turns on whether, under the facts of the particular case, the matter can move forward. He further concludes in his dissent that, in the present case, the matter is “on file and pending before the trial court” and that “we know with certainty that plaintiff will be able to proceed to the merits of that complaint.” 201 Ill. 2d at 131 (Thomas, J., dissenting, joined by Fitzgerald, J.).
We observe that Justice Thomas’ characterization of the Board’s motion as one seeking to quash service of process ignores the fact that the circuit court’s order does more than quash service, it sets aside a final judgment. In addition, it seems clear that the procedural posture of this case contradicts Justice Thomas’ view that this case is capable of moving forward.
In the present case, when the circuit court vacated the default judgment that had been entered, it did not do so merely to allow the Board to interpose a defense. The circuit court did not recognize the Board’s appearance as a general appearance and require the Board to answer. Rather, the circuit court ordered plaintiff to serve an alias summons on the Board. We know from the record that an alias summons, addressed to the Board president, was delivered to the Board and, like the original summons, was accepted by a receptionist in the Board’s law department. The Board has not filed an appearance in response to the alias summons. Moreover, appellate counsel conceded at oral argument that, should this court reverse the appellate court judgment and plaintiff attempt to proceed to trial on the underlying action, service of process on the alias summons would be contested as improper and a Rule 103(b) motion seeking dismissal with prejudice would be filed. This is the reason that the Board, though it continues to contest appellate jurisdiction over this matter, suggests in its brief that, to “avoid undue delay,” this court should exercise its supervisory authority to reach the merits of the appeal and determine whether service of process was proper.
The general appearance filed by the Board on October 1, 1997, to which Justice Thomas’ dissent makes reference, was filed in response to plaintiffs revival action, which the trial court dismissed when it vacated the default judgment as void. Thus, while, technically, the case may be pending in the circuit court, this court does not know with certainty that plaintiff will be able to proceed to the merits of the complaint. In fact, the opposite is true. Thus, even if Justice Thomas were correct in finding that Brauer did not intend to make all orders quashing service of process final and appealable orders, a matter on which we express no opinion, we observe that his rationale for finding the order here to be nonfinal is based on a misunderstanding of the posture of this case.
Service of Process
Having found no jurisdictional barrier, we address the merits of this appeal and review the trial court’s order vacating the default judgment that was entered against the Board. As noted earlier, the trial court’s vacatur order was premised on its finding that it had no jurisdiction to enter the default judgment because the Board was not served with summons in accordance with section 2 — 211 of the Code of Civil Procedure. See Ill. Rev. Stat. 1987, ch. 110, par. 2 — 211 (now codified at 735 ILCS 5/2 — 211 (West 2000)). Consequently, our review of the vacatur order requires that we determine whether summons served on the Board was in conformance with the requirements of that section.
Section 2 — 211 provides:
“In actions against public, municipal, governmental or quasi-municipal corporations, summons may be served by leaving a copy with the chairperson of the county board or county clerk in the case of a county, with the mayor or city clerk in the case of a city, with the president of the board of trustees or village clerk in the case of a village, with the supervisor or town clerk in the case of a town, and with the president or clerk or other officer corresponding thereto in the case of any other public, municipal, governmental or quasi-municipal corporation or body.” Ill. Rev. Stat. 1987, ch. 110, par. 2 — 211.
The Board is a quasi-municipal body. Thus, pursuant to statute, the Board is to be served by leaving a copy of the summons with “the president or clerk or other officer corresponding thereto.” 735 ILCS 5/2 — 211 (West 2000). Because the Board has a “president,” but no “clerk,” the parties, in attempting to establish compliance with the statute, have focused primarily on construing the language “other officer corresponding thereto.”
Plaintiff urges us to uphold the appellate court and find that “other officer corresponding thereto” is ambiguous, but may be interpreted to include the Board’s attorney, who then delegated her authority to accept service of process to her receptionist. The Board, however, argues that the term “other officer corresponding thereto,” properly construed, refers to the Board’s secretary.
As noted above, when the appellate court found that the Board’s attorney was an “other officer corresponding thereto,” it also held that the attorney could delegate the authority to accept service to the receptionist. This notion — that a person authorized by statute to accept service of process on behalf of a public entity may delegate that authority to another — was fundamental to the appellate court’s holding. However, the appellate court offered no legal support for this holding and the parties have not directly addressed the issue. In our view, however, it is essential to our resolution of the issues in this case to consider whether a person who is statutorily designated to accept service has the legal authority to delegate that duty to another, for it is of no moment whether the Board’s attorney is, as the appellate court held, an “other officer corresponding thereto” if the attorney had no legal authority to delegate her duty to accept service of process on the Board’s behalf. Similarly, if a person who is statutorily designated to accept process may legally delegate his or her authority to another, this court may consider whether, on the facts of this case, the president of the Board, who is specifically designated by statute as one who may accept service, delegated that authority, by custom and practice, to the receptionist. In that event, there would be no need to decide whether the attorney or the secretary is the “other officer corresponding thereto.” The issue of whether there was compliance with the statute would turn on whether there was sufficient evidence that the Board’s president had, by custom and practice, delegated the authority to accept process to the receptionist.
Due to its dispositive nature, we now turn to the question of whether a public entity may delegate authority to accept service of process to someone other than those persons designated by statute to accept service. We begin by acknowledging that the general and well-established rule is that strict compliance with statutes governing service of process on public entities is required. See Miller v. Town of Cicero, 225 Ill. App. 3d 105, 110 (1992), relying on Amy v. Watertown, 130 U.S. 301, 317, 32 L. Ed. 946, 952, 9 S. Ct. 530, 536 (1889). See also 56 Am. Jur. 2d Municipal Corporations § 792, at 730-31 (2000); 17 McQuillin on Municipal Corporations § 49.32, at 306 (3d rev. ed. 1993). Thus, it has generally been held that, where a statute specifies a particular officer upon whom service may be made, all others are excluded and, absent a general appearance or waiver, personal jurisdiction over the public entity will not attach unless the return of service shows that the person served is one who was statutorily authorized to accept service. See, e.g., Miller v. Town of Cicero, 225 Ill. App. 3d 105, 110 (1992) (service, to be valid, had to be on the president of the board of trustees or village clerk). Because of the necessity for strict compliance, attempts to show that summons was served on an alternate person, based on the process server’s mistaken belief that the alternate had the authority to accept service or based on the process server’s mistaken belief that the alternate was the agent of the statutorily designated person, have been unavailing. In these instances, service has been held defective, even if the public body had actual notice of the suit. See Miller, 225 Ill. App. 3d at 111 (and cases cited therein).
Notably, our review of the relevant case law has revealed no case which has squarely addressed the question of whether delegation of authority to accept service of process is permissible. However, we have found a few cases in which courts have held that service of process on someone other than the statutorily designated person was valid. In these instances, the evidence established that the public entity, either expressly or by custom, adopted an alternate means of accepting service.
Such was the case in Avery v. O’Dwyer, 201 Misc. 989, 110 N.Y.S.2d 569 (1952), mod. on other grounds, 280 A.D. 766, 113 N.Y.S.2d 686 (1952), aff’d, 305 N.Y. 658, 112 N.E.2d 428 (1953). In Avery, the evidence showed that summons was left with a clerk in the office of the corporation counsel pursuant to a sign in the office directing that service of process be made at that place. Finding that service was validly made, the Avery court said:
“Civil Practice Act, section 228 provides that, if an action is brought against the City of New York, personal service of the summons must be made by delivering a copy within the State ‘to the mayor, comptroller, or counsel to the corporation.’ It is clear that service on the corporation counsel is expressly authorized by law and constitutes service on the city. Was there service on corporation counsel in this case? I think there was unquestionably service on him. Service was made at the place and in the manner prescribed by him, presumably for his convenience and to enable him to administer his office in an orderly fashion. To treat such service as ineffectual because summons was not handed to the corporation counsel himself would be inadmissible. The corporation counsel has set up a regular system and has invited litigants to abide by and rely on that system. To permit the corporation counsel at his whim to treat service made as directed by him as not being service on him would place the public at his mercy and lead to chaos. I therefore hold that the corporation counsel was served as required.” Avery, 201 Misc. at 992, 110 N.Y.S.2d at 572.
Similarly, in Petersen v. Kansas City, 324 Mo. 454, 23 S.W.2d 1045 (1930), the court found that notice delivered to an assistant city counselor constituted service on the mayor. Although substantial compliance with the notice provision was all that was required, the court did not rule on that basis. The court found that personal service on the mayor had been achieved. The evidence had established that the mayor did not expressly authorize the assistant to accept service on his behalf, but that,
“during the previous administration the mayor had referred all such notices to the city counselor, and had given him and his assistants authority to accept service and make acknowledgments thereof for and on behalf of the mayor. The practice so inaugurated was followed by succeeding administrations and had been in vogue 10 years at the time of the acknowledgment of service entered upon the paper in question.” Petersen, 324 Mo. at 458, 23 S.W.2d at 1047.
In Crabtree v. City of Durham, 136 N.C. 816, 819, 526 S.E.2d 503, 505 (2000), the court held that, “in order to establish valid service of process, the plaintiff is not precluded from offering his own proof in addition to the officer’s return of service.” The court concluded, after considering affidavits submitted into evidence, that service of process on the secretary of the city manager, at the direction of the city manager, constituted service on the city manager.
Other courts have recognized, in principle, that delegation of authority to accept process may be permitted. Although in these cases the courts found that the evidence was insufficient to show that an agency relationship was created, the cases suggest that service on a duly delegated agent would be valid. See White v. Berryman, 187 W. Va. 323, 418 S.E.2d 917 (1992); Franz v. Board of Education of the Elwood Union Free School District, 112 A.D.2d 934, 492 N.Y.S.2d 452 (1985); Meadowdale Neighborhood Committee v. City of Edmonds, 27 Wash. App. 261, 616 P.2d 1257 (1980); Fillyow v. County of Westchester, 33 Misc. 2d 501, 225 N.Y.S.2d 848 (1961).
We conclude from these cases that the authority to accept service of process may be delegated. Thus, when service of process on a public entity is governed by a statute that designates certain persons who may accept service on behalf of the public entity, a person so designated may, either expressly or by custom, validly delegate his or her authority to accept service of process to another. Clearly, there are sound policy reasons for allowing delegation. It is often the case that a public entity, such as the Board here, will receive numerous summonses on a daily or weekly basis. As a practical matter, it may be too disruptive to the operation of the public entity to insist that all summonses be handed directly to a designated officer. Also, a person designated by statute to accept service may not be readily available. For example, in the present case, the president of the Board, who was authorized by statute to accept service, was a volunteer who was rarely at the Board offices. It may be more efficient and convenient for the public entity to put into place a specific procedure for accepting service of process. That being the case, we find that an officer designated to accept summonses on behalf of a public entity — such as the president of the Board here — may delegate the authority to accept service of process and that summons served on a duly delegated agent will constitute valid service under the statute.
Having concluded that a public entity may authorize persons to accept service of process, we now turn to the case at bar. The evidence shows that the Board was served with summons in this matter on February 1, 1988. The return of service indicates that summons was delivered to “M. Chavez,” who, it was later shown, was a receptionist in the Board’s law department and not a statutorily designated person to receive service on behalf of the Board. The question we must decide, then, is whether plaintiff presented sufficient evidence to show that the Board president, by custom and practice, delegated his authority to accept service on behalf of the Board to the receptionist. We find that plaintiff has met this burden.
Plaintiff submitted the deposition testimony of Marvin Thomas, the Cook County sheriff who served the summons in this case. Thomas testified that, in 1988, the Board was located at 1819 West Pershing. Thomas testified that, although the corporate offices of the president and secretary were on the sixth floor, whenever he served summonses on the Board in 1988, he was directed to deliver all summonses to the receptionist for the law department, located on the fifth floor. Thomas explained that, on a daily basis, he never served fewer than 25 summonses on the Board and sometimes served more than 100 summonses at a time. He said that he was always directed to deliver the summons to the law department and he did not recall ever delivering summonses to any other location within the Board.
Frank Gardner was a member of the Board from 1984 until 1989 and the Board’s president from 1987 until 1989. Gardner testified that he had never been served with process on behalf of the Board. Gardner also testified that he believed the vice-president or any other officer, in addition to anyone in the law department, could accept service for the Board and it would be considered valid service.
Norma Tsuhako testified that she was the assistant secretary to the Board from 1981 until 1993, at which time she became secretary — a position she still held at the time of her deposition in 1998. Tsuhako testified that, because the office of president was a volunteer position, the president was rarely in the office. It was her understanding that he authorized others, including the secretary of the Board and the receptionist on the sixth floor, to accept service of process on his behalf. Tsuhako testified that when she was assistant secretary, she was authorized to accept service in the secretary’s absence.
Thomas Corcoran was the secretary of the Board from 1981 to 1993. His deposition testimony established that, when he accepted service of process for the Board, he simply signed the receipt and sent the papers to the law department. Corcoran believed that the assistant secretary or the receptionist on the sixth floor had the authority to accept service.
Nancy Faulk, who had been a receptionist for the law department between 1984 and 1985, testified that when she began working as a receptionist she was told that it was her responsibility and duty to accept summonses on behalf of the Board. Faulk also testified that she continued to work for the Board, in other positions, until 1997. Throughout that time it was the Board’s practice and procedure to have the receptionist for the law department accept summonses for the Board.
Patricia Whitten, who was the Board’s chief attorney from 1982 until 1990, testified that from 1978 until 1990, and quite possibly much longer, the Board’s accepted practice was to authorize the receptionist for the law department to accept service of process on behalf of the Board. Whitten explained that she did not actually know if authority to accept process had been formally issued by the president, but that the practice had been in effect before she took office and she continued the practice throughout her tenure. Whitten also believed that she, as Board attorney, had the authority to determine the practice to be used and that she could authorize the receptionist to accept service of summonses. Thus, she believed that Chavez, who had been the receptionist in 1987 and accepted summons in this case, was authorized to accept service of process on behalf of the Board. Significantly, Whitten admitted that, in this case, once Chavez had accepted process on behalf of the Board, the summons and complaint were actually transmitted to the proper authorities, in the normal course of business.
Plaintiff also submitted into evidence a list which identified more than 30 lawsuits which had been filed in the law division of the Cook County circuit court against the Board during 1986, 1987, and 1988. The listing showed that, in each case, service of summonses was served on a receptionist for the law department and a general appearance was filed, acknowledging proper service.
We also take note that, in this case, when the Board was served with notice of the motion to revive judgment, process was served on the receptionist of the law department, whereupon the Board responded by filing a general appearance. Moreover, after the trial court granted the Board’s motion to vacate the default judgment and directed plaintiff to serve an alias summons on the Board, summons — addressed to the president of the Board — was delivered to and accepted by the receptionist of the law department.
Based on the evidence in this case, we find that plaintiff has established that service on the receptionist constituted service on the Board’s president. Although the president of the Board may not have given express consent to have the receptionist of the law department accept service of summons on his behalf in this particular instance, the evidence showed that there had been an established procedure — a custom and practice that had been in place for more than 20 years — whereby the receptionist of the law department was delegated the authority to accept service of summonses on behalf of the president.
We emphasize that our finding of proper service here is not premised on the mere fact that the Board had actual knowledge of the suit. Nor is this a situation where the litigant, in attempting to serve the defendant, served an unauthorized person due to ignorance, mistake, or misplaced reliance on false representations of employees. Here the evidence was sufficient to show that the Board put into place an alternate means of providing for acceptance of service of process. We adopt the rationale of the court in Avery and hold that, where the evidence overwhelmingly established that the Board devised a regular system to accept service of summonses and invited litigants to abide by and rely on that system, it is impermissible to allow the Board, at its whim, to treat service made as directed by it as improper service. To allow the Board to acknowledge that service was made in accord with a procedure which it put in place for the “accommodation” of the public, and then allow the Board to deny that proper service was made when the summons, though catalogued and processed in the appropriate fashion, later “fell through the cracks,” would be unjust.
For the reasons stated, we find that, based on the circumstances in this case, the receptionist of the law department was a duly delegated agent of the Board’s president for purposes of accepting service of process. Thus, summonses served on the receptionist, in accord with the procedure put in place by the Board, constituted valid service on the Board, in compliance with section 2 — 211 of the Code of Civil Procedure.
CONCLUSION
The order of the circuit court of Cook County, granting the Board’s motion to vacate the default judgment entered against it and in favor of Sarkissian, was a final, appealable order reviewable by this court pursuant to Supreme Court Rule 304(b). In addition, this court holds that the trial court erred when it found that the default judgment was void for lack of proper service of process.
For the reasons stated, we affirm the judgment of the appellate court, reversing the order of the circuit court and remanding the cause for further proceedings.
Appellate court judgment affirmed.
^though the complaint did not state Sonya’s injuries with specificity, a later pleading indicates that Sonya suffered anoxic encephalopathy (brain damage), which caused her to become a spastic quadriplegic.