Linn Farms & Timber Ltd. Partnership v. Union Pacific Railroad, 661 F.3d 354

Linn Farms owns surface rights to three Van Buren County parcels; Union Pacific owned mineral rights after a merger with Missouri Pacific.
Missouri Pacific’s address on file was not updated after the merger, so notices were mailed to Fort Worth, Texas, not Omaha, Nebraska.
The County certified delinquency and the Commissioner sent two notices to Missouri Pacific at the old Fort Worth address; both notices were returned as undeliverable.
Other Missouri Pacific/Union Pacific notices were sent to the Omaha address for different counties, with internal records showing address updates existed in some files.
The Commissioner proceeded to sell the mineral rights to Linn Farms; Linn Farms paid the delinquency and received deeds recorded in 2005.
Linn Farms sued Linn Farms v. Union Pacific and Chesapeake Exploration, seeking to quiet title; the district court granted summary judgment to Union Pacific and Chesapeake, finding the notices inadequate under due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the notice to Union Pacific satisfied due process.	Linn Farms argues notice was inadequate because the address was incorrect and no reasonable steps were taken.	Union Pacific/Chesapeake argue Arkansas law complied; due process satisfied if notice reasonably calculated to inform.	Yes, the notices were inadequate under Mullane and Jones.
What additional steps were reasonable to provide notice after notices were returned undelivered?	Linn Farms contends several steps could be reasonable; internal inquiry and further outreach.	Union Pacific argues only reasonable steps under Jones should be considered, not open-ended searches.	The Commissioner could have taken reasonable steps (internal inquiry, internet search); failure to do so violated due process.
Does compliance with Arkansas notice statute cure due process deficiency?	Even if statute compliance occurred, due process may require more.	Statutory compliance should satisfy notice requirements.	Statutory compliance does not necessarily satisfy due process; notice was still inadequate.

Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (U.S. 1950) (due process requires notice reasonably calculated to inform interested parties)
Jones v. Flowers, 547 U.S. 220 (U.S. 2006) (when notice is returned unclaimed, reasonable steps must be taken to inform the absentee)
Dusenbery v. United States, 534 U.S. 161 (U.S. 2002) (notice need not be actual, but must be reasonably calculated to provide notice)
Malone v. Robinson, 614 A.2d 33 (D.C.App. 1992) (cited for due process considerations in tax forfeiture contexts)
Greene v. Lindsey, 456 U.S. 444 (U.S. 1982) (tolerance of less-than-perfect notice standards in certain contexts)