Mathews v. Eldridge, 424 U.S. 319

Supreme Court of the United States

1976

Chapter

6

Title

Implied Fundamental Rights

Page

952

Topic

Procedural Due Process - Disability benefits do not require evidentiary hearing

Quick Notes

Eldridge benefits were terminated.  Eldridge was informed of the termination, provided statements of reasons for that termination, and given an opportunity to submit a written response to the State.   Eldridge brought suit, claiming that the procedure used by the state violated the due process clause.

Rule

o         Some form of hearing is required before deprived of property right.

o         Fundamental requirement of due process - The opportunity to be heard.

The specific dictates of due process generally requires

(1)   The private interest that will be affected by the official action;

(2)   The risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and

(3)   The Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.

Due process requires notice

o         The essence of due process is the requirement that a person in jeopardy of a serious loss be given notice of the case against him and an opportunity to meet it.

Procedures be tailored to capacity and opportunity to be heard

o         All that is necessary is that the procedures be tailored to the capacities and circumstances of those who are to be heard, to insure that they are given a meaningful opportunity to present their case.

Court - Holding

o         We conclude that an evidentiary hearing is not required prior to the termination of disability benefits and that the present administrative procedures fully comport with due process.

Book Name

Constitutional Law : Stone, Seidman, Sunstein, Tushnet.  ISBN:  978-0-7355-7719-0

Issue

o         Whether an administrative agency must always hold an individualized hearing before terminating the benefits that the agency provides to a particular citizen?  No.

Procedure

Supreme

o         The court reversed the lower court, because procedures in place were sufficient to satisfy due process, and the state of persons receiving disability benefits was typically not as serious as that of welfare recipients.

Facts/Cases

Discussion

Key Phrases

Rules/Laws

Pl -   Mathews

Df -   Eldridge

Description

o         In 1968, Eldridge began receiving disability benefits from the state in which he lived.

o         After just a few years, however, his benefits were revoked.

Terminated Benefits

o         The state agency in charge of disability benefits terminated Eldridge's benefits after considering his response to a questionnaire regarding his condition, reports from his physician and a psychiatric consultant, and Eldridge's medical files.

Notice, Response Opportunity

o         Eldridge was informed of the termination, provided statements of reasons for that termination, and given an opportunity to submit a written response to the State.

o         Eldridge provided the State with a statement disputing the agency's decision, but the benefits were nonetheless terminated.

Suit

o         Eldridge brought suit, claiming that the procedure used by the state violated the due process clause .

Justice Powell

Some form of hearing is required before deprived of property right

o         Some form of hearing is required is required before an individual is finally deprived of a property interest.

o         Procedural due process imposes constraints on governmental decisions which deprive individuals of liberty or property interests within the meaning of the Due Process Clause of the 5th or 14th Amendment.

Fundamental requirement of due process - The opportunity to be heard

o         The fundamental requirement of due process is the opportunity to be heard "at a meaningful time and in a meaningful manner."

Eldridge agrees -  Review procedures would be adequate IF

o         The review procedures available to a claimant before the initial determination of ineligibility becomes final would be adequate if disability benefits were not terminated until after the evidentiary hearing stage of the administrative process.

Dispute - what due process is required before the initial termination

o         The dispute centers, then, on what due process is due prior to the initial termination of benefits, pending review.

Extent which due process requires an evidentiary hearing

o         In recent years, this Court has increasingly had occasion to consider the extent to which due process requires an evidentiary hearing prior to the deprivation of some type of property interest even if such a hearing is provided hereafter.

Only Goldberg has required a judicial like trial

o         In only one case has the Court held that a hearing closely approximating a judicial trial is necessary.

Due process is flexible can and depends on the particular situation

o         In other cases, the Court has spoken sparingly about the requisite procedures.

o         Our decisions underscore the truism that due process is flexible and calls for such procedural protections as the particular situation demands.

The specific dictates of due process generally requires

(1)   First, the private interest that will be affected by the official action;

(2)   Second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and

(3)   Finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.

Lowers Court - Constitutionally inadequate - Required evidentiary hearing

o         Despite the elaborate character of the administrative procedures provided by the State , the courts below held them to be constitutionally inadequate, concluding that due process requires an evidentiary hearing prior to termination.

Court - Lower Courts erred

o         Only in Goldberg v. Kelly has the court held that due process requires an evidentiary hearing prior to a temporary deprivation.

Goldberg v. Kelly

o         As Goldberg illustrates, the degree of potential deprivation that may be created by a particular decision is a factor to be considered in assessing the validity of any administrative decision making process.

Private Interest Analysis

Court - In this case - potential deprivation is less than in Goldberg

o         The potential deprivation here is generally likely to be less than in Goldberg.

o         The disabled worker's need is likely to be less than that of a welfare recipient.

Court - Other forms of government assistance will be available after termination

o         In addition to the possibility of access to private resources, other forms of government assistance will become available where the termination of disability benefits places a worker below the subsistence level.

Court - Potential sources of temporary income

o         In view of these potential sources of temporary income, there is less reason here than in Goldberg to depart from the ordinary principle that something less than an evidentiary hearing is sufficient prior to adverse administrative action.

Risk of an erroneous deprivation / safeguards

Court - termination was based on unbiased medical records

o         An additional factor to be considered here is the fact that the potential value of an evidentiary hearing, or even an oral presentation to the decision-maker, is substantially less in this context than in Goldberg because the decision made here is based on unbiased medical records.

Goldberg - Written was inadequate, because they did not provide an effective means for the recipient to communicate

o         The decision in Goldberg was also based on the Court's conclusion that written submissions were an inadequate substitute for oral presentation because they did not provide an effective means for the recipient to communicate his case to the decision-maker.

Allowing full access to information relied on for termination

o         A further safeguard against mistake is the policy of allowing the disability recipient's representative full access to all information relied on by the state agency, and the state's providing a summary of the evidence that it considers most relevant to its decision.

o         Opportunity is then afforded the recipient to submit additional evidence or arguments, enabling him to challenge directly the accuracy of information in his file as well as the correctness of the agency's tentative conclusions.

Government Interest / Public Interest

Court - Administrative burden and other societal costs would be too great

o         This includes the administrative burden and other societal costs that would be associated with requiring, as a matter of constitutional right, an evidentiary hearing upon demand in all cases prior to the termination of disability benefits.

o         In this case, the administrative burden would be great, as would the financial cost, to do as Eldridge requests.

Court - Evidentiary hearing is not require

o         The Judicial model of an evidentiary hearing is neither a required, nor even the most effective, method of decision-making in all circumstances.

Due process requires notice

o         The essence of due process is the requirement that a person in jeopardy of a serious loss be given notice of the case against him and an opportunity to meet it.

Procedures be tailored to capacity and opportunity to be heard

o         All that is necessary is that the procedures be tailored to the capacities and circumstances of those who are to be heard, to insure that they are given a meaningful opportunity to present their case.

Court - Holding

o         We conclude that an evidentiary hearing is not required prior to the termination of disability benefits and that the present administrative procedures fully comport with due process.

Reversed

DISSENT - Justice Brennan

No argument

o         The Court's consideration that a discontinuance of disability benefits may cause the recipient to suffer only a limited deprivation is no argument.

o         It is speculative.

Legislature provided benefits, Court cannot denigrate [to attack]

o         Moreover, the very legislative determination to provide disability benefits, without any prerequisite determination of need in fact, presumes a need by the recipient which is not this Court's function to denigrate.

Untenable to say a work may still seek other forms of public assistance

o         Finally, it is also no argument that a worker, who has been placed in the untenable position of having been denied disability benefits, may still seek other forms of public assistance.

o         Eldridge home and furniture were repossessed

o         Family had to sleep in one bed

Rules

The specific dictates of due process generally requires

(1)   First, the private interest that will be affected by the official action;

(2)   Second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and

(3)   Finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.

Class Notes