1. SHAUMYAN v. O’NEILL, 987 F.2d 122 (2d Cir.1993), involved the same attachment statute at issue in Doehr, but applied in a contract dispute between a homeowner and a contractor hired to do repairs. The homeowner questioned the quality of the repair work, and refused to pay the remainder of the bill. The contractor moved ex parte in state court and obtained a prejudgment attachment against the owner’s home. While the state court action was pending, the homeowner sued in federal court to enjoin enforcement of the statute as violative of due process. Both the district court and the Court of Appeals rejected the constitutional challenge. Although the homeowner had a strong private interest, the likelihood of an erroneous deprivation was not high because the evidence largely involved written documentation; moreover,258the contractor “had a substantial pre-existing interest”

in the property once his labor and materials had been incorporated into plaintiff’s home. Id. at 127. See Alquist, Balancing the Checklist: Connecticut’s Legislative Response to Connecticut v. Doehr, 26 Conn. L. Rev. 721 (1994).