PHH Mortgage Corp. v. Prater, 133 Ohio St. 3d 91

PHH Mortgage filed foreclosure against Michael Prater in 2008; default judgment and foreclosure granted.
Initial sheriff’s sale dates were scheduled and withdrawn at PHH’s request; PHH received notice by mail of each date.
In December 2009 the sheriff advised that notices would be posted online rather than mailed to attorneys.
Fourth sale was scheduled for April 6, 2010; sale occurred and Wolf purchased the property.
PHH moved to set aside the sale asserting no written notice of the sale date/time/location; trial court denied.
Ohio Court of Appeals affirmed; Ohio Supreme Court reversed, holding online posting insufficient for due process when address is known.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does online sheriff’s posting satisfy due process when address is known?	PHH argues notice via website is insufficient.	Wolf argues notice was provided through the new system directing monitoring of the site.	No; online posting insufficient for due process.
Is notice to a party's attorney effective notice to the party itself?	PHH treats attorney notice as notice to the party.	Wolf contends an attorney-directed method suffices.	Yes, it is treated as notice to the party; however, not sufficient here.
Is constructive notice by publication via the Internet equivalent to newspaper publication for due process purposes?	PHH relies on traditional publication as a baseline; asserts Internet notice is publication-like.	Wolf emphasizes accessibility and continuity of online notices.	No; Internet posting is not reasonably calculated to provide actual notice.

Mullane v. Cent. Hanover Bank & Trust Co., 339 U.S. 306 (U.S. 1950) (due process requires notice reasonably calculated to inform interested parties)
Mennonite Bd. of Missions v. Adams, 462 U.S. 791 (U.S. 1983) (mailing to last known address must supplement publication)
Cent. Trust Co., N.A. v. Jensen, 67 Ohio St.3d 140 (Ohio 1993) (addressable party cannot be effectively notices by publication alone)