In Civil Service Assn. v. City and County of San Francisco (1978) 22 Cal.3d 552, the Supreme Court considered whether employees suspended for five days or less were entitled to the Skelly v. State Personnel Bd. (1975) procedural safeguards in advance of that suspension. The court concluded that such predisciplinary procedures are not required in the case of minor suspensions. The court then went on to say, however, that "minimal concepts of fair play and justice embodied in the concept of due process require that there be a 'hearing,' of the type hereinafter explained," either during the suspension or within a reasonable time thereafter (p. 564). The court then explained the character of the postdisciplinary "hearing" which would satisfy due process, that is, one that will apprise the employee of the discipline and the reasons therefor, give the employee a copy of the charges including materials upon which the action is based, and give the employee the right to respond, either orally or in writing, to the charges.