California, United States of America
The following excerpt is from In re Emily R. & Kern Cnty. Dept. of Human Serv. V. Michael U., 80 Cal.App.4th 1344, 96 Cal.Rptr.2d 285 (Cal. App. 2000):
"But when notice is a person's due, process which is a mere gesture is not due process. The means employed must be such as one desirous of actually informing the absentee might reasonably adopt to accomplish it. The reasonableness and hence the constitutional validity of any chosen method may be defended on the ground that it is in itself reasonably certain to inform those affected, [citations], or, where conditions do not reasonably permit such notice, that the form chosen is not substantially less likely to bring home notice than other of the feasible and customary substitutes." (Mullane v. Central Hanover Tr. Co., supra, 339 U.S. at p. 315.)
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