In the case of Sandra Gardebring, Commissioner of the Minnesota Department of Human Services v. Kathryn Jenkins (1987), the U.S Supreme Court addressed a dispute over welfare benefits. The plaintiff, Kathryn Jenkins, argued that her benefits were unjustly reduced by the state's Department of Human Services due to an incorrect interpretation and application of federal law regarding income calculations for Aid to Families with Dependent Children (AFDC). She claimed this violated both her constitutional rights and provisions under Social Security Act. However, in a unanimous decision led by Justice Thurgood Marshall, it was ruled that states have considerable discretion in determining how they calculate available income for AFDC purposes as long as their methods are reasonable and fully explained to recipients. Therefore, Minnesota’s method did not violate federal law or constitutionally protected property interests.

In the dissenting opinion for Sandra Gardebring, Commissioner of the Minnesota Department of Human Services v. Kathryn Jenkins, Justice O'Connor argued that the majority's decision was inconsistent with previous rulings and expanded federal jurisdiction over state matters in a way that could have far-reaching implications. She contended that there was no violation of due process because Jenkins had received notice and an opportunity to be heard before her benefits were terminated. Furthermore, she asserted that any delay in receiving post-termination hearings did not constitute irreparable harm as long as retroactive relief was available. The justice also expressed concern about potential negative impacts on states' administrative processes and budgets if they were required to provide immediate post-termination hearings for all welfare recipients.