In City of West Covina v. Perkins, the United States Supreme Court ruled that the Due Process Clause of the Fourteenth Amendment does not require law enforcement officers to give property owners notice of the State law remedies available to retrieve property lawfully seized in criminal investigations. The note argues that Perkins correctly rejected the Ninth Circuit's expansive notice requirement because it was unwarranted and unsupported by precedent. It further argues that the Court's decision will not have an adverse impact on future property deprivation cases if it is properly limited to seizures similar to those in Perkins. However, the note claims, the majority should have based its "notice of seizure" requirement, discussed in dicta, on the principles espoused by the Fourth Amendment's requirement for specific warrants and its guarantee against unreasonable seizures, rather than on the Due Process Clause of the Fourteenth Amendment. Notes