Mullane v. Central Hanover Bank & Trust Co.

Summary

The Supreme Court considered whether publication-only notice to beneficiaries in a judicial settlement of a common trust fund account satisfied the Due Process Clause of the Fourteenth Amendment. It held that publication was inadequate for known beneficiaries whose names and addresses were known, while recognizing publication as sufficient for beneficiaries whose interests or whereabouts were unknown, and reversed the judgment.

Holdings

1. Before a proceeding that may finally deprive a person of life, liberty, or property, due process requires notice reasonably calculated under all the circumstances to apprise interested parties of the proceeding and afford them an opportunity to present objections.
2. Publication notice alone was constitutionally inadequate for known present beneficiaries whose names and post-office addresses were known to the trustee; notice by ordinary mail to those record addresses was required.
3. Publication notice was sufficient for beneficiaries whose interests or whereabouts were unknown to the trustee, including beneficiaries with conjectural or future interests when more certain notice was impracticable.

Questions Presented

1. Whether New York's statutory publication notice for judicial settlement of a common trust fund account satisfied the Fourteenth Amendment's due process requirements.
2. Whether publication alone was constitutionally sufficient for beneficiaries whose names and addresses were known to the trustee.
3. Whether the State could use publication notice for beneficiaries whose identities or addresses were unknown, or whose interests were conjectural or future.

Disposition

reversed_and_remanded