It is almost universally accepted that providing notice of a hearing date to a non-citizen's attorney is sufficient to notify the non-citizen of the hearing date. The Sixth Circuit, however, is expressing some reluctance to find that notice to an attorney ALWAYS suffices to notify the client of a hearing date. Though the court was willing to accept that providing written notice to the attorney in open court, while the client is present, is legally sufficient, it called into question whether mailing a notice to an attorney, without first trying to serve the non-citizen directly with the notice, would suffice. "To summarize, we interpret [the statute] to require that personal service be made upon the alien whenever practicable and hold that, in certain cases, personal service to a represented alien’s counsel may constitute personal service to the alien." This case may provide valuable analysis for attorneys filing motions to reopen based on insufficient notice when a client's prior attorney was served with the notice.
The full text of Cruz-Gomez v. Lynch can be found here: http://www.ca6.uscourts.gov/opinions.pdf/15a0229p-06.pdf