In Robinson v. Hanrahan, the U.S. Supreme Court ruled that a notice of forfeiture proceedings sent to an individual's home address while they were incarcerated did not constitute adequate notification under the Due Process Clause of the Fourteenth Amendment. The case involved Johnnie Lee Robinson, whose car was seized by Illinois police following his arrest for murder and other crimes in 1969. While he was in jail awaiting trial, state officials initiated forfeiture proceedings against his vehicle but only mailed notice to his home address rather than delivering it directly to him in prison. As a result, Robinson didn't learn about these proceedings until after they had concluded and his car had been sold at auction without giving him any opportunity to contest this action or recover any proceeds from the sale.

In the dissenting opinion for Robinson v. Hanrahan, Justice William O. Douglas argued that due process was violated when a notice of forfeiture proceedings against an individual's property was sent by mail to their residence and not personally served. He believed this method did not adequately ensure that the person would receive such important information in time to defend themselves or their property rights in court. In his view, sending a letter is insufficient because it can be lost or misdelivered, and there is no guarantee that it will reach its intended recipient promptly if at all. Therefore, he contended that personal service should have been used as it provides more assurance of actual receipt of notice than mailing does.