The Arizona Supreme Court held in State v. Zaman, 194 Ariz. 442 (1999) that personal service by a deputy sheriff of a non-Indian located on an Indian reservation is valid and reaffirmed previous decisions that such service on an Indian is invalid. Justice Jones in concurrence noted that alternative methods of service should be employed to avoid conflicts involving service of process by state officials on Indian reservations. He noted that private process servers and requests for waiver of service are currently available alternatives. Service by certified mail is currently available only if the party is located outside of Arizona.