In Mathews v. Eldridge, 424 U.S. 319, 96 S. Ct. 893, 47 L. Ed. 2d 18 (1976), the Seventh Circuit determined that Chicago's system did not violate due process because the "the benefits of requiring the ticket writer to appear at every hearing are unlikely to exceed the costs." Id. at 1352. Regarding the benefits, the Seventh Circuit determined that there was only a small likelihood that requiring the ticket writer's presence would prevent an erroneous result--i.e., that an innocent driver would be forced to pay a fine. Id. at 1351-52. As to the costs, the Seventh Circuit found that requiring the ticket writer's presence would cause Chicago to incur substantial monetary costs, diminish the deterrent efficacy of the parking laws, and deprive Chicago of revenues to which it was entitled. Id. at 1351. The Seventh Circuit further explained: Assuming that oral testimony is more persuasive in general than written, the only basis on which the plaintiffs can complain about the ticket writer's absence is that it prevents them from cross-examining him. In short, they are claiming that they have a right of confrontation. There is no absolute right of confrontation in civil cases. In particular cases, live testimony and cross-examination might be so important as to be required by due process, although the principal case so holding--Goldberg v. Kelly, 397 U.S. 254, 268, 90 S.Ct. 1011, 1020-21, 25 L.Ed.2d 287 (1970)--may not have much life left after Mathews. Goldberg granted a right of confrontation to persons denied welfare benefits; Mathews withdrew it for persons denied disability benefits. The basis for distinction was the hardship to persons taken off welfare, and of course it has no counterpart here. Moreover, the ordinance empowers the hearing examiner to subpoena witnesses. That provides an adequate safety valve for those cases, if any (there may be none), in which fair consideration of the respondent's defense would require, as a constitutional imperative, the recognition of a right of confrontation. Id. at 1352 In Mathews, the Supreme Court set forth the following factors for determining the procedural minima required by due process: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. Mathews, 424 U.S. at 335. It was stated that due process is a flexible concept requiring different levels of protection in different circumstances (see Mathews v. Eldridge, 424 U.S. 319, supra, at 334). In general, three factors must be considered when deciding whether due process requirements have been satisfied: (1) the private interest affected by the state's action; (2) the risk of an erroneous deprivation of that interest through the procedures used and the probable value, if any, of additional safeguards; (3) a consideration of the government's interest (see id., at 335). The Court held that due process did not require an evidentiary hearing before termination of disability benefits under the Social Security Act. It concluded that because eligibility for disability benefits was not based on financial need, as was welfare eligibility, and the person whose disability benefits were cut off prior to a hearing would not necessarily be deprived of the very means to live while awaiting a hearing, due process was met by posttermination hearing. ( Id., at pp. 340-341.) The Supreme Court stated the general requirements applicable to due process in administrative procedures, in the context of the procedures for the termination of Social Security disability benefits. It held that "identification of the specific dictates of due process generally requires consideration of three distinct factors: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. " (Mathews v. Eldridge, supra, 424 U.S. 319, 335.) The court also noted that continuance of disability benefits was premised in most cases on reliable standard medical reports, so that the potential value of an evidentiary hearing was far less than in welfare cases. ( Id. , at pp. 343-344.) The California Supreme Court has enumerated the factors to be considered in analyzing the extent to which due process requires notice and hearing prior to the deprivation of some type of property interest: "first, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail." ( P. 335.)