Dow v. Michigan

In Dow v. Michigan, 396 Mich 192, 211; 240 NW2d 450 (1976), the Supreme Court of Michigan addressed the notice that must be given to property owners before extinguishing their redemption right. Rejecting the adequacy of service by publication, the Court explained: Personal service is not required. Notice by mail is adequate. Mailed notice must be directed to an address reasonably calculated to reach the person entitled to notice. Mailing should be by registered or certified mail, return receipt requested, both because of the greater care in delivery and because of the record of mailing and receipt or non-receipt provided. Such would be the efforts one desirous of actually informing another might reasonably employ. If the state exerts reasonable efforts, then failure to effectuate actual notice would not preclude foreclosure of the statutory lien and indefeasible vesting of title on expiration of the redemption period.