6. In GREENE v. LINDSEY, 456 U.S. 444, 102 S.Ct. 1874, 72 L.Ed.2d 249 (1982), the Court addressed the constitutionality of eviction notices posted on apartment doors in public housing. The tenants claimed never to have seen the notices, and to have first learned of their eviction when served with writs of possession after default judgments had been entered against them. A divided Supreme Court held that in the circumstances of this case, service by mail was required:

As the process servers were well aware, notices posted on apartment doors in the area where these tenants lived were “not infrequently” removed by children or other tenants before they could have their intended effect. Under these conditions, notice by posting on the apartment door cannot be considered a “reliable means of acquainting interested parties of the fact that their rights are before the courts.”