Wednesday, April 25, 2012

Preposterous Forms Vindicated

"Citation by publication is not a favored method of service of process because it is the least calculated to notify the defendant of the pendency of a judicial action,"Graves v. Graves, 916 S.W.2d 65, 68 (Tex. App.—Houston [1st Dist.] 1996, no writ) (citing Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306, 313-315 (1950)), and it is "a constitutionally permissible form of notice where there are no other means available to put on notice a defendant who cannot be found." In re AY, 16 S.W.3d 387, 389 (Tex. App.—El Paso 2000, no pet.) (also citing Mullane).

I actually found a few examples of cases where the defendants received notice by way of citation by publication. See Bavousett v. Bradshaw, 332 S.W.2d 155, 159 (Tex. Civ. App.Amarillo 1959, writ ref'd n.r.e.); Mathis v. Coker, No. 10-05-00437-CV, n. 2 (Tex. App.Waco 2007, no writ).

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