In the Mennonite Board of Missions v. Adams case in 1982, the U.S Supreme Court ruled that mortgage holders must be notified personally before their property is sold at a tax sale. The court held that sending notice by mail or other means to ensure it's received satisfies due process requirements under the Fourteenth Amendment. This decision came after Elkhart County, Indiana sold property owned by Mennonite Board of Missions at a tax sale without providing personal notification about the pending sale. Instead, they published an announcement in local newspapers and posted notices on bulletin boards around town which was deemed insufficient according to constitutional standards for notice-and-hearing procedures.

In the dissenting opinion for Mennonite Board of Missions v. Adams, Justice Blackmun argued that due process does not require actual notice in every instance but rather a method reasonably calculated to provide notice. He contended that Indiana's tax sale statute did meet this standard as it provided two notices by mail and publication before the property was sold. Furthermore, he noted that there is an obligation on mortgagees to protect their security interests and they should bear some responsibility for keeping informed about potential threats to those interests such as tax sales. Therefore, he disagreed with the majority’s view that additional efforts must be made by government officials beyond what was already required under state law.