In the Interest of E.R.

When the State seeks to sever permanently the relationship between a parent and a child, it must first observe fundamentally fair procedures.1 The most basic of these is notice. If the State cannot deliver notice in person, it may try other means that will likely reach the parent.2 We consider today whether serving the parent in a newspaper advertisement, “a *555poor and sometimes a hopeless substitute for actual service,”3 is constitutionally acceptable when the State knew the mother’s identity, was in regular contact with her, and had at least one in-person meeting with her after it sued to…