## Facts

- Heights Medical Center sued Roy Peralta in Texas state court to collect on Peralta’s guarantee of an employee’s hospital debt.
- Peralta did not appear, and a default judgment was entered against him.
- The judgment was recorded, creating a lien on Peralta’s real property; a writ of execution issued.
- Peralta’s real property was sold to satisfy the judgment.
- Peralta filed a Texas bill of review seeking to set aside the default judgment and void the sale, alleging defective service and lack of personal notice.
- The trial court granted summary judgment for Heights because Peralta did not show a meritorious defense to the underlying debt claim; Peralta conceded he lacked such a defense.
- Texas appellate courts affirmed, and the Texas Supreme Court declined further review.
- The U.S. Supreme Court noted probable jurisdiction and reviewed whether Texas could bar relief on a meritorious-defense requirement where notice was constitutionally inadequate.

## Issues

1. Whether due process permits a state to condition relief from a default judgment entered without constitutionally adequate notice or service on the defendant’s showing of a meritorious defense.
2. Whether lack of prejudice on the merits (because the defendant would likely lose anyway) can justify leaving intact a judgment obtained without proper notice.

## Decision

- The Court reversed.
- Due process requires notice and an opportunity to be heard before the State may deprive a person of property through judgment and its enforcement mechanisms.
- A default judgment entered without constitutionally adequate notice cannot be insulated from attack by requiring the defendant to prove a meritorious defense.
- The absence of a substantive defense does not render the lack of notice harmless because the defendant may have had meaningful options affecting impleader, settlement, payment, or the manner and timing of satisfying the obligation.
- The recorded judgment and resulting lien imposed independent legal harms, including impairing Peralta’s ability to mortgage or transfer the property and enabling execution and sale without notice.

## Legal Principles

- The Due Process Clause requires constitutionally adequate notice and a meaningful opportunity to be heard before property is taken through judicial process.
- A state may not treat a judgment obtained without proper notice as valid based on post hoc assumptions that the defendant would have lost on the merits.
- When notice is constitutionally defective, conditioning set-aside relief on proving a meritorious defense violates due process because it denies the right to be heard on interests beyond ultimate liability.
- Entry and recording of a judgment and lien can constitute a distinct deprivation with legal consequences, regardless of whether the underlying debt is owed.

## Conclusion

The Court held that Texas violated due process by denying relief from a default judgment entered without constitutionally adequate notice solely because the defendant could not show a meritorious defense, and it reversed for further proceedings consistent with that rule.


Peralta v. Heights Med. Ctr., Inc., 485 U.S. 80 (1988)