In Goldberg v. Kelly (1970) 397 U.S. 254 25 L. Ed. 2d 287, 90 S. Ct. 1011, New York City officials administering a welfare program were terminating recipients' benefits without a pre-termination hearing. ( Id. at pp. 255-257 25 L. Ed. 2d at pp. 292-293.) Although public assistance benefits are a privilege and not a constitutional right, the court held that welfare recipients had an "important right" to receive welfare benefits, which right could not be terminated by city authorities without a pre-termination due process hearing in light of the "crucial factor" of the recipients' "desperate" need for those benefits, which are necessary for daily subsistence. (Id. at pp. 261-264 25 L. Ed. 2d at pp. 295-297.)