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OCR: "Notice of Pendency of Action" on the day the cormplaint was fi led. See Hawaii Rev Stat. $501 -151. Further scizure prevent alienation was unnecessary In the two cases in the last quarter century where this court considered due prxess issues in connection with forfei. ture Catero- -Toledo and $8850 the court rejected, at least by implication. the government Fourth Amendment argu ent Calera -Totedo, the an explicit balancing following Fuentes analysis Shevin justify the The entire seizure analysis without wou]d hearing have er unnecessary the Fourth iment simply made nO tice and hearing superfluous In $8850. the court found necessary to explain why nQ hearing was by due process before the initial seizure by referring the impracticality of such hearing again applying the Fuentes test 461 U. ...