Jackson did not explicitly determine what type of jurisdiction was being exercised here, but held that the Fourteenth Amendment applied to all of them regardless of how the state classified the action. The beneficiaries' property rights were at stake here, and without proper notice, the "right to be heard" provided by the Fourteenth Amendment was of no practical consequence. Constructive service via newspaper publication, wrote Jackson, was an unreliable method of giving notice, because newspapers have limited circulation and even then, many people do not examine the legal notices, which are usually in small typeface on the back pages. In this case, the legal notice at issue did not even mention the names of the beneficiaries. Furthermore, under normal circumstances, property holders are directly aware of legal proceedings regarding their property, either directly or through a caretaker. But in this case, the caretaker was the beneficiaries' adversary - the trustee itself - which could not be expected to give them reasonable notice, and the special guardian was also not required to give notice.