On this date in 1983, a unanimous Supreme Court decided Callen v. Sherman’s, Inc., 92 N.J. 114 (1983). The case involved whether distraint, a procedure that allowed commercial landlords to seize, or even sell, without notice or hearing, property of a tenant who owes rent, violated due process. As Justice Pollock noted in the Court’s opinion, “since at least the thirteenth century, the common law has condoned distraint as an exception to the principle that ‘self-help is an enemy of the law, a contempt of the king and his court.'” New Jersey had a distraint...