The Supreme Court declared that “[a]n elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to be heard.” Mullane, 339 U.S. at 314. The Supreme Court recognized, however, that actual notice is not always possible. It therefore held that due process requires actual notice to known parties but that for unknown parties, reasonable publication notice is sufficient.
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