the European setting, the links between reasonableness and integrated proportionality will no doubt continue. For example, in a letter to Member States addressing the global financial crisis, the Committee confirmed the “requirement” of proportionality, by calling for all policies confronting the crisis to “be necessary and proportionate, in the sense that the adoption of any other policy, or a failure to act, would be more detrimental to economic, social and cultural rights.” 131 A proportionality-inflected standard of reasonableness may draw from the relevant examples from Europe, which include the Latvian Court’s rejection of social security reforms made in the absence of “objective and well-weighted analysis” of the economic and social consequences of the reforms, and of other less restrictive means.132 Similarly, in Hungary, among the Constitutional Court’s earliest cases was a holding that the citizen’s legitimate expectations and confidence in the legal system required a serious consideration of different means to social security reform, and not merely application of reforms “practically overnight”. 133 A recent addition to this line of examples is the well-known rejection, by the German Constitutional Court, of cuts to social security reached by a random, rather than evidencebased, inquiry.134 131 Letter dated 16 May 2012 addressed by the Chairperson of the Committee on Economic, Social and Cultural Rights to States parties to the International Covenant on Economic, Social and Cultural Rights (May 16, 2012), http://www2.ohchr.org/english/bodies/cescr/docs/LetterCESCRtoSP16.05.12.pdf. 132 Contiades & Fotiadou, supra note 21, 697, discussing Judgment of the Constitutional Court of the Republic of Latvia, on 21 December 2009, in the case No. 2009-43-01. 133 Id., at 677, see also BEATTY, supra note 64, 143; On Social Security Benefits (1995). 134 Bundesverfassungsgericht [BVerfG] [Federal Constitutional Court] 9 Feb. 2010 (Hartz IV), 125 ENTSCHEIDUNGEN DES BUNDESVERFASSUNGSGERICHTS [BVERFGE] 175 (__), 1 BVL 1/09, para. 1–220, 2010 (Ger.), available in English at http://www.bundesverfassungsgericht.de/SharedDocs/Entscheidungen/EN/2010/02/ls20100209_1bvl00010 9en.html (last visited June 2, 2016). 33