In Memphis Light, Gas & Water Div. v. Craft (1978) 436 U.S. 1, the Supreme Court held that a municipal utility's failure to include in a notice that a customer's failure to make an overdue payment would result in termination of service, advice "of the availability of a procedure for protesting a proposed termination of utility service as unjustified" did not "comport with constitutional requirements" of due process. (Craft, supra, 436 U.S. at pp. 14-15.) The court reached this conclusion after considering "three distinct factors" specified in Mathews v. Eldridge (1976) 424 U.S. 319, 334-335: " '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.' " (Craft, at pp. 17-18.) Utilizing this balancing approach, the court concluded that "because of the failure to provide notice reasonably calculated to apprise the customer of the availability of an administrative procedure to consider their complaint of erroneous billing, and the failure to afford them an opportunity to present their complaint to a designated employee empowered to review disputed bills and rectify error, the utility deprived the customer of an interest in property without due process of law." (Id. at p. 21.)