In Beckler v. North Dakota Workers Comp. Bureau, 418 N.W.2d 770 (N.D. 1988), the Court held the Bureau denied Beckler due process of law because its "procedures did not give Beckler a pretermination notice that his disability benefits would be terminated, a summary of the medical evidence supporting termination, and an opportunity to respond." Id. at 775. A benefit recipient's pretermination opportunity to respond may "be limited to a written submission as an initial check against an erroneous decision" if the Bureau conducts "a timely post-termination evidentiary hearing" and it has "authority to award retroactive disability benefits." Id.