The majority stated that welfare benefits are property and articulated the general proposition that welfare enjoys the same legal protection as other property. Justice Brennan noted that welfare benefits are "a matter of statutory entitlement for persons qualified to receive them" and added that "it may be realistic today to regard welfare entitlements as more like 'property' than a 'gratuity.'" Here Brennan cited Charles A. Reich's article "The New Property". The prohibition against deprivation of property without due process of law in the Fourteenth Amendment therefore applies to benefits termination.