What is the current state of the law on garnishment and seizure of a person's personal property?

The seminal case of Sniadach itself held merely that wage garnishment without prior hearing was unconstitutional, leaving for later resolution the constitutionality of other remedies. Fuentes v. Shevin (1972) 407 U.S. 67, 92 S.Ct. 1983, 32 L.Ed.2d 556, a four-to-three decision, struck down Florida and Pennsylvania replevin statutes on the ground that 'They allow summary seizure of a person's possessions when no more than private gain is directly at stake,' (p. 92, 92 S.Ct. p. 2000) asserting that a Preseizure hearing was essential except in 'extraordinary . . . truly unusual' situations. (407 U.S. at p. 90, 92 S.Ct. 1983.)