Archie McCoy v. Hawaii Department of Human Services, et al.
1. In proceedings to terminate parental rights, before a court permits constructive service by publication does the Fourteenth Amendment's Due Process Clause require further efforts by the government, beyond a mother's limited reports about the absent father, to locate the father?
2. In proceedings to terminate parental rights, does the Due Process Clause require further efforts by the government when it becomes aware, prior to the termination, that its service of process by publication has failed to provide notice?
3. Does the Due Process Clause require that a court appoint legal counsel to an indigent "unknown" parent facing termination of parental rights?
Does the Fourteenth Amendment's Due Process Clause require further efforts by the government to locate an absent father before permitting constructive service by publication in parental rights termination proceedings?