In the case D. H. Overmyer Co., Inc., of Ohio et al. v. Frick Co, 1971, the U.S Supreme Court ruled on a dispute involving contract law and due process rights under the Fourteenth Amendment to the Constitution. The Overmyer Company had signed a "cognovit note," which is an agreement that allows one party (Frick) to make legal decisions without notifying or getting approval from another party (Overmyer). When Overmyer defaulted on its debt payments, Frick used this cognovit note to obtain judgment against them in court without their knowledge or participation. The Supreme Court held that there was no violation of due process because Overmyer voluntarily waived its right by signing such an agreement with full understanding of what it entailed and having been represented by counsel during negotiations for these terms; thus they were not deprived of property without due process as claimed in their appeal.

In the dissenting opinion for D. H. Overmyer Co., Inc., of Ohio et al. v. Frick Co, Justice William O. Douglas argued that the "cognovit" clause in a loan agreement, which allows a creditor to enter judgment against a debtor without notice or hearing if the debtor defaults on payment, was inherently coercive and violated due process rights under the Fourteenth Amendment of U.S Constitution regardless of whether it was voluntarily agreed upon by both parties involved in contract negotiation. Douglas contended that such clauses were historically viewed with suspicion because they could be used to exploit vulnerable debtors who might not fully understand their implications or have equal bargaining power during negotiations. He also pointed out that while many states had banned cognovits altogether due to these concerns, others only allowed them under strict regulations designed to ensure fairness and transparency - conditions he believed were not met in this case. Therefore, he disagreed with majority's decision upholding validity of cognovit clause based solely on its voluntary nature as per contractual law principles rather than considering broader constitutional issues at stake.