In Dixon, Secretary of State of Illinois v. Love (1976), the U.S. Supreme Court upheld an Illinois law that allowed for the suspension or revocation of a driver's license without providing a pre-suspension hearing to the individual affected. The case was brought by Love, who had his commercial driving privileges revoked after multiple traffic violations and convictions under this law. He argued that he was denied due process because he did not receive a hearing before his license was suspended. The court ruled in favor of Dixon, stating that due process does not always require a hearing prior to deprivation of a significant property interest if there is some post-deprivation remedy available and if pre-deprivation hearings would impose an undue burden on the state. In this case, it found that drivers have ample opportunity to contest any traffic violation charges against them at their initial trials and can also request full administrative review following any suspension or revocation decision made by the Secretary.

In the dissenting opinion for Dixon, Secretary of State of Illinois v. Love (1976), Justice William J. Brennan Jr., joined by Justices Thurgood Marshall and Potter Stewart, argued that the majority's decision failed to adequately protect individuals' due process rights. They contended that an individual's driver's license could not be suspended without a hearing simply because they had been convicted of multiple traffic offenses in different jurisdictions over time. The dissenting justices believed this violated procedural due process protections under the Fourteenth Amendment as it did not provide sufficient notice or opportunity to challenge the suspension before it took effect. They also disagreed with the majority’s view that driving is a privilege rather than a right, arguing instead that modern society has made driving essential for many people’s livelihoods and thus should be treated as more than just a privilege.