In Driver v. Housing Authority (2006) 289 Wis.2d 727, 713 N.W.2d 670 ( Driver ), cited by Johnson, the court recognized that while " Goldberg might allow for 'actual or constructive notice,' " the federal regulations adopted to implement the section 8 program "contemplated 'an arguably higher standard of "what process is due." ' " ( Id. at p. 743, 713 N.W.2d 670, citing Morales v. McMahon (1990) 223 Cal.App.3d 184, 190, 272 Cal.Rptr. 688.) The court explained that the federal regulations "mandate written notice, and strict compliance is imperative as a matter of law and public policy." ( Driver , at p. 732, 713 N.W.2d 670.) The court explained, "Because of the informality surrounding the pre-termination hearing process, courts may have little or no record upon which to ascertain the sufficiency of oral or other *614actual notice.... Faced with such a sparse record, a section 8 recipient who attempts to establish that he or she did not receive oral notice faces a nearly insurmountable task. Courts would likely infer actual notice in many cases from the mere opportunity of the plaintiff to discover the pertinent information (i.e., constructive notice) combined with the housing authority's assertion that he or she in fact exercised that opportunity, at which time it provided oral notice. Thus, an 'actual notice' exception would not adequately protect a section 8 recipient's property right in his or her benefits." ( Id. at pp. 744-745, 713 N.W.2d 670.)