ges founded upon a wrong
inflicted on the citizen by the nonresident. Being neither present
within the State nor domiciled therein, the nonresident defendant cannot
be served personally; and consequently any judgment in money obtained
against him would be void and could not thereafter be satisfied either
by execution on the nonresident's property subsequently found within the
State or by suit and execution thereon in another State. In such
instances, the citizen-plaintiff may recover, if at all, only by an _in
rem_ proceeding involving a levy of a writ of attachment on the local
property of the defendant, of which proceeding the nonresident need be
notified merely by publication of a notice within the forum State.
However, any judgment rendered in such proceedings can have no
consequence beyond the property attached. If the attached property be
insufficient to pay the claim, the plaintiff cannot thereafter sue on
such judgment to collect an unpaid balance; and if property owned by the
defendant cannot be found within the State, the attachment proceedings
are, of course, summarily concluded.[728]

Actions in Rem--Corporations, Estates, Trusts, Etc.--Probate
administration, being in the nature of a proceeding _in rem_, is one to
which all the world is charged with notice.[729] Thus, in a proceeding
against an estate involving a suit against an administratrix to
foreclose a mortgage executed by the decedent, the heir, notwithstanding
that the suit presents an adverse claim the disposition of which may be
destructive of his title to land deriving from the decedent, may
properly be represented by the administratrix and is not entitled to
personal notification or summons.[730] For like reasons, a statutory
proceeding whereunder a special administrator, having charge of an
estate pending a contest as to the validity of the will, is empowered
to have a final settlement of his accounts without notice to the
distributees, is not violative of due process. The executor, or
administrator c.t.a., has an opportunity to contest the final settlement
of the special administrator before giving the latter an acquittance;
and since the former represents all claiming under the will, it cannot
be said the absence of notice to the distributees of the settlement
deprives them of their rights without due process of law.[731]

In litigation to determine succession to property by proceedings in
escheat, due process is afforded by personal service