The following excerpt is from Lopez v. Henry Phipps Plaza South, Inc., 498 F.2d 937 (2nd Cir. 1974):
3 It must be recognized, however, that allowing hearings in refusal-to-renew cases poses a problem not present in welfare termination and many other types of cases involving termination of a governmentally bestowed benefitnamely, the unwillingness of fellow tenants to testify for fear of reprisal and the hostility between groups of tenants that may be engendered. See Note, supra, 86 Harv. L.Rev. at 906-07. As there suggested, such factors may require some restriction of the right of confrontation, along lines such as those suggested by the Chief Justice in Morrissey v. Brewer, supra, at 487. We leave such questions for another day.
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