Louis Brandeis, American Surety Company v. Baldwin Baldwin…
“ The surety company contends in No. 21 that, even if the trial court of the state had jurisdiction, the federal District Court may enjoin the enforcement of the judgment on the ground that, having been entered without notice and an opportunity for a hearing on the construction of the bond, it lacked due process of law. It is true that entry of judgment without notice may be a denial of due process even where there is jurisdiction over the person and subject-matter. ”
