Mathews, Secretary of Health, Education and Welfare v. Eldridge

424 U.S. 319 (1976)

Justice POWELL delivered the opinion.

Facts:

  • Respondent (Eldridge) was receiving disability benefits since June 1968.
  • Eldridge filled out a questionnaire in March of 1972 indicating his condition had not improved.
  • After considering his answers as well as physician and psychiatric reports, the agency informed Eldridge in writing about its tentative determination that his disability had ceased in May 1972.
  • Eldridge contested one characterization of his medical condition
  • The agency made its final determination that Eldridge’s disability had ceased in May 1972. This decision was accepted by the SSA, which notified Eldridge in July that his benefits would cease after that month.       He was also notified of the right to seek reconsideration within 6 months.
  • When the disability payments ceased, Elbridge’s furniture was repossessed. 

Procedural History:

  • Eldridge challenged the constitutionality of the Secretary of Health, Education and Welfare’s procedure for terminating disability payments.
  • Courts below SC find for Eldridge
  • Court of Appeals judged in favor of Eldridge

Issue:

  1. Does Due Process require an evidentiary hearing prior to terminating disability payments?
  2. The extent to which due process requires an evidentiary hearing prior to depravation of some property interest even if such a hearing is provided after termination.

Holding:

  1. NO

No evidentiary hearing is necessary beforeterminating Social Security benefits

Rule:

  1. Due process does not require an evidentiary hearing prior to depravation of property interest if certain safeguards to due process are in place.

Reasoning:

* The Court has consistently held that some type of opportunity to be heard “at a meaningful time and in a meaningful manner” was required before someone was finally deprived of a property interest.

* Goldberg v. Kelly is the only case (among those discussed by the Court) in which a pre-termination evidentiary hearing was required to meet the standard of due process.

* Due process should be interpreted in accordance to the situation and three factors:

  1. The private interest (Eldridge) that will be affected by the action (termination).
  2. The risk of error in depriving under the present process and value of additional procedural safeguards (pre-termination hearing) in reducing the risk of error.
  3. The Government’s fiscal and administrative interests.

* The Court argues that in Goldberg v. Kelly the private interest and risk of error outweighed the Govt. interest, the same is not true in the case of disability: Eldridge is distinguishable from Goldberg:

  1. The depravation is likely to be less in a case of disability than in a case of welfare, because (a) welfare is based on need, while disability is not. (b) While a disability recipient may resort to other sources of aid, welfare is often the last resort for a claimant. A disability claimant can also claim welfare. (c) Even though the process of reinstating disability may take over 1 year, it is not enough to trump the other factors.
  2. The risk of error in pre-termination procedures in a disability termination is lower than that in a welfare termination, because the former depend on standard medical reports. In Eldridge, the common disability recipient is (a) more educated, the written reports are (b) objective, and the (c) credibility of witnesses is not at stake. The potential value of a pre-termination hearing in disability is much less valuable than in welfare and would be extraordinarily costly given the length of disability termination-dispute procedures.
  3. The cost, fiscally and administratively, “would not be insubstantial.” Need as much $$ as possible to distribute among needy.

* Because this case cannot be evaluated in the same way as a welfare case, the Court holds that the procedural safeguards in place are sufficient to meet the standard of due process.

Court’s Order:

Judgment of Court of Appeals reversed

Dissent:

Justice BRENNAN and MARSHALL

Court’s consideration in 1 is speculative and no argument

It is not Court’s place to make policy decisions

New Information, questions, etc:

This opinion sets the current standard for determining whether the government has violated due process:

  1. The private interest
  2. The risk of error in depriving under the present process and value of additional procedural safeguards in reducing risk of error
  3. The Government’s interests