Jones v. Flowers
United States Supreme Court
547 U.S. 220 (2006)
Gary Jones (plaintiff) fell behind on property taxes for his Little Rock home, and the state land commissioner, Mark Wilcox (defendant), sent certified mail warning that the property would be sold if Jones didn't pay within two years; that letter came back marked "unclaimed." Two years later, Wilcox published a notice of sale in the newspaper, got no response, and arranged a private sale to Linda Flowers (defendant); a second certified letter to Jones was also returned unclaimed before the sale closed. Flowers personally served a detainer notice, which Jones's daughter accepted, and Jones learned of the sale only then. He sued in Arkansas state court, arguing the notice process was constitutionally inadequate; the trial court and Arkansas Supreme Court both ruled against him.
Whether notice of a tax sale by certified mail is constitutionally sufficient when the state knows that mailing was ineffective.