for hearings to those whose aid was scheduled for termination, the State of New York implemented a hearing procedure after commencement of Kelly's litigation. The decision answered questions that had been unresolved in the previous Supreme Court cases of Rudder v. United States and Thorpe v. Housing Authority of Durham. The cases involved questions of denial of tenancy or eviction in governmental housing projects. It has been noted that the precarious financial status of those in poverty may preclude an extensive litigation process despite the decision. The abstention doctrine presupposes the adequacy of state process to protect constitutional rights. Poor people may lack the funds to pursue a court hearing process. One solution has been the use of a preliminary injunction, which preserves the status quo while the litigation proceeds. See also Administrative Procedure Act (United States) Due Process Redistributive change Perry v. Sindermann, 408 U.S. 593 (1972) Mathews v. Eldridge, 424 U.S. 319 (1976) References External links United States Supreme Court cases United States Supreme Court cases of the Burger Court United States civil due process case law United States administrative case law 1970 in United States case law American Civil Liberties Union litigation Social Security lawsuits