a few weeks before the public sale, the Commissioner published a notice of public sale in the Arkansas Democrat-Gazette. No bids were submitted, which permitted the State to negotiate a private sale of the property. Several months later, Linda Flowers submitted a purchase offer. The Commissioner mailed another certified letter to Jones at the house, attempting to notify him that his house would be sold to Flowers if he did not pay his taxes. Like the first letter, the second was also returned to the Commissioner marked "unclaimed." Flowers subsequently purchased the house at approximately a quarter of its fair market value. Immediately after the 30-day period for postsale redemption passed, Flowers had an unlawful detainer notice delivered to the property. The notice was served on Jones' daughter, who contacted Jones and notified him of the unpaid taxes and the tax sale. State court proceedings Jones filed a lawsuit in Pulaski County Circuit Court against the Commissioner and Flowers, alleging that the Commissioner's failure to provide notice of the tax sale and of Jones' right to redeem resulted in the taking of his property without due process. The Commissioner and Flowers moved for summary judgment on the ground that the two unclaimed letters sent by the Commissioner were a constitutionally adequate attempt at notice, and Jones filed a cross-motion for summary judgment. The trial court granted summary judgment in favor of the Commissioner and Flowers, concluding that the Arkansas tax sale statute, which set forth the notice procedure followed by the Commissioner, complied with constitutional due process requirements. Jones appealed, and the Arkansas Supreme Court affirmed the trial court's judgment. The court noted Supreme Court precedent stating that due process does not require actual notice, and that attempting to provide notice by certified mail satisfied due process in the circumstances presented. Opinion of the Court The Supreme Court granted certiorari to resolve a conflict among the Circuits and state supreme courts concerning whether the Due Process Clause requires the government to take additional reasonable steps to notify a property owner when notice of a tax sale is returned undelivered. The United States Solicitor General was granted leave to participate as amicus curiae, and argued in support of the Commissioner's position. In a five-justice opinion delivered by Chief Justice John G. Roberts, the Court reversed the Arkansas Supreme Court and ruled that, under the circumstances, the State's sale of Jones' property