Robert J. Sweet v. Philip L. Berge

Philip and Betty Jo Berge appeal from an order making a judgment of strict foreclosure of a land contract absolute. The Berges contend that their failure to receive notice of the redemption period substantially prior to its expiration violated their right to procedural due process under the fourteenth amendment to the United States Constitution. The Berges also assert that since the redemption period ended on a legal holiday, the trial court erred in entering the order less than twenty-four hours after the end of the holiday. Because we conclude that the Berges received sufficient notice of all proceedings leading to the strict foreclosure judgment and subsequent order, and because the trial court had the authority to enter the order on June 1, 1982, we affirm the order.