Publication Date



Decades ago the Supreme Court articulated that due
process requires adopting a means of service that one
would naturally adopt if he actually desired to inform
another. For generations newspaper publication has been
allowed where the party to be notified is not known or
cannot be located. But, given the rapid transformation

of information dissemination over our country's recent
history, are newspapers a method that anyone would use if
they truly wanted to relay information to another person?
This Note examines the shift in how American's receive
news and information in our modern society. It explores
the decline in newspaper readership, the rise of Internet
communication, and the historical mobility of our society.
Based on the continuous decline in newspaper use and the
unstoppable expansion of the Internet, this Note concludes
that newspapers are not a method of communication that
anyone desiring to notify another party would reasonably
use. Therefore, notice by newspaper publication no longer
meets the constitutional standard for due process.
This Note concludes by proposing a method of
notification that embraces the new ways in which society
communicates and emboldens proactive citizens to harness
the power of electronic applications and services to
monitor challenges to their property rights. Given the

efficacy of modern-day technology in reaching people, this
Note encourages the Court to modify the Federal Rules
and leverage modern advancements to better protect each
citizen's constitutional right to notification and an
opportunity to be heard.