The purpose of this article is to identify and examine the influencing considerations and the attachment of significance given to them by the courts in the "due-on" cases. After a discussion of recent litigation addressing the enforceability of the "due-on" clauses in Virginia, a summarizing checklist will follow detailing the factors which must be considered by the practitioner preparing to draft or litigate the clause.
W. Wade Berryhill, The Due-On-Sale Clause: A Marriage Gone Sour - A Checklist For The Practitioner, 16 U. Rich. L. Rev. 35 (1981).