In Fuentes v. Shevin, 407 U.S. 67 (1972), deputy sheriffs seized the plaintiffs' properties, including kitchen appliances, electronics, furniture, clothing, and children's toys, before the plaintiffs "had even received a summons to answer the complaints." Id. at 70-72. The U.S. Supreme Court examined Florida's and Pennsylvania's prejudgment replevin provisions regarding the lack of due process. Id. at 69-70. Both statutes provided for the issuance of writs ordering state agents to seize a person's possessions, simply upon the ex parte application of any other person who claimed a right to them and posted a security bond. Neither statute provided for notice to be given to the possessor of the property, and neither statute gave the possessor an opportunity to challenge the seizure at any kind of prior hearing. Id. Accordingly, the U.S. Supreme Court concluded that the statutes were unconstitutional. Id. at 96.