Standard Oil Co. v. New Jersey

In Standard Oil Co. v. New Jersey (1951) 341 U.S. 428, the United States Supreme Court considered the constitutionality of a New Jersey statute that permitted escheatment to the state of certain abandoned personal property. The statute required the state to publish a notice in a newspaper for three successive weeks identifying the property sought to be escheated and the name of the last known owner. (Id. at p. 433.) The Supreme Court rejected a due process challenge to the statute on the ground that the statutory notice provision was inadequate. (Id. at p. 431.) In reaching this conclusion, the court reasoned: "The sound reasons stated in the foregoing cases Security Sav. Bank, 263 U.S. 282 and Mullane, supra, 339 U.S. 306 for deeming the notices there given adequate to bind interested persons in the respective proceedings, lead us to the conclusion that the notice by publication in this case was adequate. If the state has the responsibility of looking after abandoned property subject to its sovereign power, these publications are adequate to affect the owner's rights." (Id. at pp. 434-435.) In sum, the United States Supreme Court has held that notice by publication is generally a sufficient method by which to alert owners of unclaimed property that the state seeks to take title to their property. (Standard Oil, supra, 341 U.S. at pp. 434-435)