n16 Although the majority accurately states this "'black letter'" law, it also acknowledges that courts will avoid a foreclosure sale for a price that "shocks the conscience," see ante, at 11, a standard that has been invoked to justify setting aside sales yielding as much as 87% of appraised value. See generally R. Washburn, The Judicial and Legislative Response to Price Inadequacy in Mortgage Foreclosure Sales, 53 S. Cal. L. Rev. 843, 862-870 (1980). Moreover, while price inadequacy "alone" may not be enough to set aside a sale, such inadequacy will often induce a court to undertake a sort of "strict scrutiny" of a sale's compliance with state procedures. See, e.g., id., at 861.