In Jones v. Flowers, 547 U.S. 220 (2006), the Arkansas Commissioner of State Lands ("Commissioner") mailed a certified letter to the defendant to notify him of his tax delinquency. The letter stated that unless the defendant redeemed the property, the property would be subject to public sale two years later. No one was home to sign for the letter and nobody retrieved the letter from the post office within the next fifteen days. The post office returned the unopened letter to the Commissioner marked "unclaimed." Id. at 224, 164 L. Ed. 2d at 424. Two years later, the Commissioner published a notice of public sale in the newspaper several weeks before the sale. No bids were submitted, permitting the State to negotiate a private sale of the property. Several months later, Linda Flowers submitted a purchase offer. The Commissioner then mailed another certified letter to the defendant, attempting to notify him that his house would be sold to Flowers if he did not redeem the property. Like the first letter, the second was also returned to the Commissioner marked "unclaimed." Id. The property was subsequently sold to Flowers. The defendant filed suit against the Commissioner and Flowers, alleging that the Commissioner's failure to provide notice of the tax sale and of the defendant's right to redeem his property resulted in the taking of his property without due process. The United States Supreme Court held that "when mailed notice of a tax sale is returned unclaimed, the State must take additional reasonable steps to attempt to provide notice to the property owner before selling his property, if it is practicable to do so." Id. at 225. The Court reasoned that "despite the fact that the letters were reasonably calculated to reach their intended recipients when delivered to the postman," id. at 229, when the notice provider becomes aware that normal procedures are ineffective in providing notice, this triggers an obligation "to take additional steps to effect notice." Id. at 230. The Court then determined that "under the circumstances presented , additional reasonable steps were available to the State." Id. at 225. The Court held that when the government becomes aware prior to the taking that its attempt at notice has failed, due process requires the government to "take additional reasonable steps to attempt to provide notice to the property owner before selling his property, if it is practicable to do so." (547 US at 225.) Jones involved the certified mailing of a notice of tax sale to a property owner, that was returned unclaimed. The record indicated that the property owner moved out of the house when he and his wife separated, and seven years later, the Arkansas Commissioner of State Lands sent him a certified letter as to the tax delinquency, at the address of the property; two years after that, another certified letter was sent to him at the same address, advising that his house would be sold if he did not pay his taxes. The certified letters were returned marked "unclaimed," and the Commissioner took no further steps to notify the property owner. The United States Supreme Court concluded that "the Commissioner's effort to provide notice to the property owner of an impending tax sale of his house was insufficient to satisfy due process given the circumstances of this case." (Id. at 239.) The Court found that "although the State may have made a reasonable calculation of how to reach the property owner, it had good reason to suspect when the notice was returned that the property owner was no better off than if the notice had never been sent.' Deciding to take no further action is not what someone desirous of actually informing' the property owner would do; such a person would take further reasonable steps if any were available." (Id. at 230.) "What steps are reasonable in response to new information depends upon what the new information reveals." Id. Analyzing the "new information," the Court in Jones reasoned that the return of the certified letters marked "unclaimed" meant either that the property owner still lived at the property but was not at home when the postal carrier called and did not retrieve the letter at the post office, or that the property owner no longer resided at that address. (Id.) Based on that information, the Court determined that several additional reasonable steps at notice were available, including resending the notice by regular mail, posting the notice on the front door or addressing otherwise undeliverable mail to "occupant." (Id. at 234-235.)