By Robert Millner and Geoffrey Miller (March 22, 2018, 1:13 PM EDT) -- On Jan. 26, 2018, in Dahlin v. Lyondell Chemical Co.,[1] the Eighth Circuit addressed the issue of what content is required to be included in a publication notice, to unknown creditors, of a claim bar date. The Eight Circuit in Dahlin, reversing the district court, found that notice, to an unknown toxic tort plaintiff exposed to benzine 14 to 19 years before the Chapter 11 filing at a facility then operated by an unaffiliated predecessor of the debtor, that lists names used by debtor entities within eight years of the filing, complies with the federal bankruptcy rules and constitutional due process. The decision made clear that due process, in the notice context, is rooted in reasonableness. The Dahlin court relied on Mullane v. Central Hanover Bank & Trust Co.,[2] (due process requires "notice reasonably calculated under all circumstances to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections."), and In re Placid Oil Co.,[3] ("We have never required bar date notices to contain information about specific potential claims.").   ...