The U.S. Supreme Court case Atkins, Commissioner of the Massachusetts Department of Public Welfare v. Parker et al., 1984 centered around whether or not a state could reduce or terminate welfare benefits without first providing recipients with an evidentiary hearing. The court ruled in favor of Atkins, stating that due process does not require an evidentiary hearing before reducing public assistance benefits under the Aid to Families with Dependent Children (AFDC) program and Food Stamp Act. Instead, it was deemed sufficient for states to provide notice and an opportunity for beneficiaries to present written objections prior to any reduction or termination of aid. This decision upheld Massachusetts' administrative procedures as constitutional despite claims from recipients who argued their rights were violated when their benefits were reduced without a pre-termination hearing.

In the dissenting opinion for Atkins v. Parker, Justice O'Connor disagreed with the majority's interpretation of Section 602(a)(19) of the Social Security Act. She argued that this provision does not require states to provide a pre-termination hearing before reducing or terminating welfare benefits due to changes in federal law. Instead, she believed it only requires notice and an opportunity for a hearing when there is a question about whether recipients are still eligible under existing rules. According to her, Congress did not intend this section to apply when eligibility standards themselves change because such changes affect all recipients equally and do not involve individualized determinations of eligibility. Therefore, she concluded that Massachusetts' reduction in benefits without providing pre-termination hearings did not violate federal law.