339 U.S. 306 (U.S. 1950)
Mullane v. Central Hanover Bank & Trust Co.
Does notice by publication alone satisfy due process in a judicial trust accounting where many beneficiaries are known and their addresses are known or reasonably ascertainable, and more generally, what constitutional standard governs the adequacy of notice?
Due process requires notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present objections. The means employed must be such as one desirous of actually informing the absentee might reasonably adopt. Actual notice is not required, but mere gestures that are not likely to reach those who could be informed are insufficient. When names and addresses are known or reasonably ascertainable through due diligence, at least notice by mail is required; publication may suffice only for persons whose identities or whereabouts cannot with reasonable effort be determined.
Notice by publication alone violated due process as to known beneficiaries whose names and addresses were known or reasonably ascertainable; mailed notice (or equivalent) to those beneficiaries was constitutionally required. Publication was sufficient for beneficiaries who were unknown or whose addresses could not be discovered with due diligence. Representation by a guardian ad litem did not cure the failure to provide adequate notice. The judgment was affirmed in part and reversed in part, and remanded for proceedings consistent with this standard.
Mullane is the bedrock authority on procedural due process notice. Its reasonably calculated standard governs across civil procedure, trusts and estates, class actions, foreclosures, and administrative enforcement. The decision requires governments and litigants to use superior, feasible methods—typically mail—when parties are known or easily reachable, while allowing publication for those who are not. Mullane's pragmatic approach has guided later cases such as Mennonite Board of Missions v. Adams (requiring mailed notice to a reasonably ascertainable mortgagee), Dusenbery v. United States (actual notice not mandatory; method must be reasonably calculated), and Jones v. Flowers (requiring reasonable follow-up when mailed notice is returned unclaimed). For law students, Mullane frames how courts assess notice sufficiency, the limits of jurisdictional labels, and how judgments bind absent parties.