Summary creditor remedies have come under increasing attack in recent years. The major question has been whether prejudgment seizures of secured property comport with procedural due process. The United States Supreme Court, in Fuentes v. Shevin, had apparently settled the question by holding that procedural due process requires notice to the debtor and an opportunity to be heard before a state authorizes its agents to seize property from him on the application of another.
Constitutional Law-Due Process-Ex Parte Seizure of Secured Property Under Judicial Supervision Held Not to Violate Due Process,
U. Rich. L. Rev.
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