are sufficiently represented by the corporation.[736]

Actions in Rem--Divorce Proceedings.--The jurisdictional
requirements for rendering a valid decree in divorce proceedings are
considered under the full faith and credit clause. _See_ pp. 662-670.

Misnomer of Defendant--False Return, Etc.--An unattainable
standard of accuracy is not imposed by the due process clause. If a
defendant within the jurisdiction is served personally with process in
which his name is misspelled, he cannot safely ignore it on account of
the misnomer. If he fails to appear and plead the misnomer in abatement,
the judgment binds him. In a published notice intended to reach absent
or nonresident defendants, where the name is a principal means of
identifying the person concerned, somewhat different considerations
obtain. The general rule, in case of constructive service of process by
publication, tends to strictness. However, published notice to "Albert
Guilfuss, Assignee," in a suit to partition land, was adequate to render
a judgment binding on "Albert B. Geilfuss, Assignee," the latter not
having appeared.[737]

Foreclosure of a mortgage made upon process duly issued but which the
sheriff falsely returned as having been duly served, and of which the
owner had no notice, does not deprive said owner of property without due
process of law. A purchaser of the land at the sheriff's sale has a
right to rely on such return; otherwise judicial proceedings could never
be relied upon. The mortgagor must seek his remedy against the sheriff
upon his bond.[738]

Notice and Hearing

Legislative Proceedings.--While due notice and a reasonable
opportunity to be heard to present one's claim or defense have been
declared to be two fundamental conditions almost universally prescribed
in all systems of law established by civilized countries,[739] there are
certain proceedings appropriate for the determination of various rights
in which the enjoyment of these two privileges has not been deemed to be
constitutionally necessary. Thus the Constitution does not require
legislative assemblies to discharge their functions in town meeting
style; and it would be manifestly impracticable to accord every one
affected by a proposed rule of conduct a voice in its adoption. Advanced
notice of legislation accordingly is not essential to due process of
law; nor need legislative bodies preface their enactment of legislation
by first holding committee hearings thereon. It