Procedural due process claim related to the defendant-City’s demolition of the building on the plaintiffs’ commercial property; U.S. Const. amend XIV; “Notice”; Mullane v. Central Hanover Bank & Trust Co.; Karkoukli’s, Inc. v. Dohany; Mennonite Bd. of Missions v. Adams; Tulsa Prof’l Collection Servs., Inc. v. Pope; Jones v. Flowers; Posted notices; Greene v. Lindsey; Post-hearing notice; McKinney v. Pate (11th Cir.)

[This appeal was from the WD-MI.] The court held that the plaintiffs-property owners (the Yangs) received adequate notice before the defendant-City of Wyoming demolished their “dilapidated” commercial building. The city sent notice through signature-required certified mail, but the letter was returned unclaimed. Then, “the city made four other attempts to reach the Yangs on top of the certified mail it sent to the couple’s home address.” Notices were posted on the Yangs’ building, and they received a notice regarding the demolition hearing by regular mail. This hearing notice was also forwarded to the Yangs’ realtor. After the hearing and before the demolition, the city sent them an additional letter by regular mail. “All of these forms of notice considered, the city satisfied due process before tearing down a building that even the Yangs do not deny was dangerous and dilapidated.” The court rejected the Yangs’ “divide and conquer approach” in attacking the adequacy of notice, noting that “neither Jones nor any other case holds that the city acts unreasonably simply because its subsequent responses would not—each by themselves—independently satisfy due process . . . .” At “some point, the question must turn from how often—and in how many forms—notice is due to how many times the property owner neglects to respond with the diligence that is due. Either way, the city satisfied its reasonableness requirements.” The fact that the Yangs “chose (apparently) not to visit their property for fourteen months or chose (apparently) not to open their mail does not diminish the city’s reasonable efforts at providing notice. ‘The law expects at least some diligence from the property owner,’ . . . and that reality necessarily affects how courts gauge reasonable efforts.” The court affirmed the district court’s grant of summary judgment to the city.