When a property owner fails to pay real estate taxes, due process requires that the state make reasonable efforts to notify the owner of the resulting foreclosure proceeding. State and local statutory schemes often require the state to notify the owner by regular or certified mail. But if the notification is returned unclaimed or undeliverable, must the state make additional efforts to notify the owner? In <i>Jones v. Flowers</i>, 2006 U.S. Lexis 3451, the Supreme Court recently addressed this question, and held that when notice of a tax sale, sent certified mail, is returned to the state unclaimed, the due process clause requires the State to take 'additional reasonable steps' to provide notice to the property owner prior to the sale. The language of the Jones opinion casts doubt on the validity of the leading New York case on this issue, <i>Kennedy v. Mossafa</i>, 100 N.Y.2d 1.
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We want to know how we can make this newsletter an even better resource for your professional needs. Are we covering all you want to see? Are there sections you would like to see enhanced or replaced?<br>Your views and opinions are essential in our effort to continue to provide you with the top notch News, Strategy and Analysis you have come to expect from Law Journal Newsletters.<br>Help us help you! Please click <a href="http://www.surveymonkey.com/s.asp?u=604771980045">here</a> to complete a short survey or type the following URL into your browser: http://www.surveymonkey.com/s.asp?u=604771980045.<br>Your answers will assist us in making this an even better newsletter for you! Thank you.<br>Regards,<br>Colin Graf<br>LJN Marketing Director
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