3. In MITCHELL v. W.T. GRANT CO., 416 U.S. 600, 94 S.Ct. 1895, 40 L.Ed.2d 406 (1974), the Court upheld a Louisiana sequestration statute permitting the creditor to obtain the writ on an ex parte application without giving the debtor either notice or a prior opportunity for a hearing. The suit involved an overdue balance for personal property bought under an installment sales contract. The Court reasoned that the risk of a wrongful taking was minimized by the vendor’s interest in preventing waste of the property, the judicial authorization of the writ, and the immediate availability of a postseizure hearing. However, in NORTH GEORGIA FINISHING, INC. v. DI–CHEM, INC., 419 U.S. 601, 95 S.Ct. 719, 42 L.Ed.2d 751 (1975), the Court invalidated a Georgia garnishment statute that permitted the writ to be issued on the basis of conclusory allegations without providing defendant an “early”

hearing “or other safeguard against mistaken repossession.” Id. at 606, 95 S.Ct. at 722, 40 L.Ed.2d at 757.