Congregation Yetev Lev D'Satmar v. County of Sullivan

In Congregation Yetev Lev D'Satmar v. County of Sullivan, 59 NY2d 418 [1983], the Court of Appeals held that "due process requires only that the notice be appropriate to the nature of the case without creating impossible or impractical obstacles to concluding the proceedings." The Plaintiff had obtained title to the property through adverse possession, and as a result, did not receive actual notice of the tax sale. The Court found that constructive notice was acceptable because the address of an owner by adverse possession was not "reasonably identifiable" and the assessor was not required to undertake "extraordinary efforts to discover the claim of adverse possession.