In the 1893 case of Lewis v. Monson, the U.S Supreme Court was tasked with determining whether a Connecticut law that allowed for property seizure without prior notice or hearing violated due process under the Fourteenth Amendment. The plaintiff, Lewis, had his property seized by Monson to repay a debt and argued this action was unconstitutional. However, the court ruled in favor of Monson stating that due process does not necessarily require advance notice and opportunity for hearing before possession is taken of an individual's property to satisfy a debt. Instead, it held that if there is sufficient subsequent opportunity for a complete judicial determination on the merits after seizure has been made then no violation occurs. This ruling established precedent regarding what constitutes as "due process" in relation to seizures and collections.

In the dissenting opinion for Lewis v. Monson, it was argued that the majority's decision to uphold a state law prohibiting non-residents from fishing in its waters violated the Privileges and Immunities Clause of Article IV of the Constitution. The dissenting justices believed that this clause guaranteed citizens of each state all privileges and immunities granted to citizens in other states, including access to natural resources such as fish. They contended that while states have authority over their own resources, they cannot discriminate against out-of-state residents by denying them rights enjoyed by in-state residents without just cause. In this case, they felt there was no valid reason given for barring non-residents from fishing; therefore, it constituted unjust discrimination based on residency status.