In this paper I propose to identify possible ways in which a court could uphold the constitutionality of section 9-503 without an explicit rejection of Fuentes v. Shevin. It is my thesis that Fuentes v. Shevin is probably an undesirable outcome, and that the application of the same doctrine to self-help repossession is certainly undesirable and would constitute due process gone berserk. My arguments will not be novel; each has been suggested by the courts that have considered this matter, or by the briefs of the lawyers who have argued these cases. I cannot even claim to have collected the data upon which I rely in the last part of the paper; that task was accomplished by Professor Robert Johnson, who has presented it as an appendix" to an amicus brief in Adams v. Egley.
White, James J. "The Abolition of Self-Help Repossession: The Poor Pay Even More." Wis. L. Rev. 1973 (1973): 503-31.