From Martin v. Raffin, 21 N.Y.S. 1043 (N.Y. City Ct. 1893):
The defendant resides in Tremont; the process server called there twice to serve him with the summons herein, and some other papers. On his second visit he found the defendant actually in the shelter of his wife’s petticoats, he having sought that means of protection for the purpose of avoiding service of the summons herein. While in that position he was invited to accept service of the said summons, which he refused to do. The summons, and other legal papers, were then laid upon his shoulder, and he shook them to the floor.
Held, service was proper, and involved neither an “assault upon defendant’s person” nor a “trick.” The conduct of the defendant, however, was “reprehensible” in the view of the court. The thoughts of the defendant’s wife on the matter are not recorded.