findings of fact or conclusions of law but should state the reasons for his determination and indicate the evidence he relied on. (e) The decision maker must be impartial, and although prior involvement in some aspects of a case will not necessarily bar a welfare official from acting as decision maker, he should not have participated in making the determination under review. Discussion The Goldberg decision set the parameters for procedural due process when dealing with the deprivation of a government benefit or entitlement. The Court held that a person has a property interest in certain government entitlements, which require notice and a hearing before a governmental entity (either state or federal) takes them away. Government-provided entitlements from the modern welfare state increased substantially in the United States during the 20th century. The Goldberg court decided that such entitlements (like welfare payments, government pensions, professional licenses), are a form of "new property" that require pre-deprivation procedural protection and so did away with the traditional distinction between rights and privileges. The majority stated that welfare benefits are property and articulated the general proposition that welfare enjoys the same legal protection as other property. Justice Brennan noted that welfare benefits are "a matter of statutory entitlement for persons qualified to receive them" and added that "it may be realistic today to regard welfare entitlements as more like 'property' than a 'gratuity.'" Here Brennan cited Charles A. Reich's article "The New Property". The prohibition against deprivation of property without due process of law in the Fourteenth Amendment therefore applies to benefits termination. This specific case dealt with 20 individuals who had been suspected of welfare fraud by New York City officials and were then denied municipal benefits. The opinion of the Court was delivered by Justice William Brennan, while dissenting opinions were filed by Justices Hugo Black and Potter Stewart and Chief Justice Warren Burger. Brennan said at his retirement that he considered it the most important case he had ever decided; conservative columnist David Frum once claimed that the case was a major factor in New York City's 1975 budget meltdown. John Kelly, acting on behalf of New York residents receiving financial assistance either under the federally assisted program for Families with Dependent Children or under New York State's home relief program, challenged the constitutionality of procedures for notice and termination of such aid. Although originally offering no official notice or opportunity