In Connecticut v. Doehr (1991) 501 U.S. 1, a case involving a prejudgment attachment procedure, the United States Supreme Court set forth a test for determining whether a procedure by which a private party invokes state power to deprive another person of property satisfies due process: "First, consideration of the private interest that will be affected by the procedure; second, an examination of the risk of erroneous deprivation through the procedures under attack and the probable value of additional or alternative safeguards; and third, ... principal attention to the interest of the party seeking the procedure, with, nonetheless, due regard for any ancillary interest the government may have in providing the procedure or forgoing the added burden of providing greater protections." (Id. at p. 11.) In Connecticut v. Doehr, a statute permitted plaintiffs in civil suits to obtain ex parte attachments against defendants with a showing so minimal--an averment by the plaintiff that the defendant is liable--that it resulted in a "significant risk of erroneous deprivation." (Doehr, supra, 501 U.S. 1, 21.) The court noted the statute enabled one of the private parties to "'make use of state procedures with the overt, significant assistance of state officials,'" that involve state action "'substantial enough to implicate the Due Process Clause.'" (Id. at p. 11.) The court concluded that, absent exigent circumstances, the private party's interest in attaching the property did not justify the burdening of the private property owner's rights without a hearing to determine the likelihood of recovery. (Doehr, supra, at p. 18.)