California, United States of America
The following excerpt is from La Opinion, In re, 10 Cal.App.3d 1012, 89 Cal.Rptr. 404 (Cal. App. 1970):
Due process is satisfied in those circumstances where notice by publication is sufficient, not because of the likelihood that publication will give actual notice, but because publication satisfies the legal fiction. (See Walker v. Hutchinson, 352 U.S. 112, 116, 77 S.Ct. 200, 202, 1 L.Ed.2d 178: 'It is common knowledge that mere newspaper publication rarely informs a landowner of proceedings against his property.'
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