the Republican party had taken over Congress the year prior, LSC had its funding cut again, from $400 million to $278 million. A new set of much more extensive restrictions were added to LSC grantees. The organization's supporters expressed disappointment that the Clinton administration did not make LSC a critical priority in its budget battles with the Republican Congress, especially given Hillary Clinton's former role in it. As part of a comprehensive "welfare reform" of federal welfare laws beginning in 1996, most significantly the Personal Responsibility and Work Opportunity Act, Congress imposed restrictions on the types of work that LSC grantee legal services organizations could engage in. For example, LSC-funded organizations could no longer serve as counsel in class action lawsuits challenging the way public benefits are administered. Additionally, LSC grantees faced tightened restrictions on representing immigrants, specifically those illegally in the country. However, in 2001, the restriction on welfare advocacy was ruled unconstitutional in Legal Services Corp. v. Velazquez. However, non-LSC funded organizations are not subject to these restrictions leading the legal services community to adopt a two-track approach: LSC restricted counsel taking on individual clients but not engaging in class actions, and non-restricted counsel (using private donor funding) both taking on individuals as well as engaging in otherwise restricted litigation. Poverty lawyers in both tracks still work together where they can, being careful not to run afoul of LSC restrictions. George W. Bush era In 2004, veteran Legal Aid Society attorney Helaine M. Barnett was named President of the LSC. According to LSC's 2009 report "Documenting the Justice Gap in America: The Current Unmet Civil Legal Needs of Low-Income Americans," all legal aid offices nationwide, LSC-funded or not, were together able to meet only about 20 percent of the estimated legal needs of low-income people in the United States. For 2007, LSC had a budget of some $350 million. Obama era In 2009 during the Obama administration, the LSC was on the path to getting a $50 million increase in its $390 million budget. However, the LSC came under criticism from Senator Charles Grassley, who said, "There's just a lot of money being wasted," citing several General Accounting Office and Inspector General reports. At the same time, Congress rolled back the restriction that LSC-funded attorneys could not take attorneys' fees-generating cases; LSC finalized the regulation in 2010 after President Obama signed an appropriations bill into law. By fiscal