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

Brief Fact Summary. Respondent Eldridge, under the Due Process Clause of the Fifth Amendment of the United States Constitution, challenged the lack of a full-trial evidentiary hearing before his disability benefits were terminated.

Synopsis of Rule of Law. The Court, in determining whether pre-termination procedural rules are adequate, will weigh private interests, public interests and the reliability of the procedures.

Facts. Respondent was first awarded Social Security benefits in June 1968 and in March of 1972 the state agency run by Petitioner Mathews send Respondent a questionnaire to monitor Respondent’s medical condition. After receiving the questionnaire and information from his physician, Petitioner stopped his disability payments in May 1972. At that time he was allowed to submit additional information, which he did. The agency still proposed continuing payments, and the Social Security Administration approved their findings. Respondent then had an opportunity to seek reconsideration, but he instead brought this action to challenge the validity of a procedural system that would take away his benefits prior to a full evidentiary hearing. Petitioner argued that he failed to exhaust his remedies, but Respondent analogized his situation to a person who is trying to collect welfare (which requires a pre-termination hearing).

Issue. The issue is whether the current procedures are adequate in ensuring that Respondent’s rights to due process are met.

Held. The majority of the United States Supreme Court held that the current procedural format is adequate and does not violate Respondent’s rights of due process. Although Respondent would lose benefits while appealing the termination, he would be entitled to receiving any lost payments if he is successful in getting them reinstated. Respondent’s situation is also different from a welfare recipient who is more likely to need the payments while arguing the merits of their case. The court applied three factors to determine if the current procedural rules were adequate: whether the private interests were protected, whether the public’s interests were protected, and whether the rules are reliable in producing an accurate outcome. In this case, the procedural rules weigh favorably.

Dissent. The dissent argues that the majority does not understand the significance that the termination of disability payments could have on a party while adjudicating their claim. The dissent cites the current Respondent who had a foreclosure on his home while fighting the termination.

Discussion. The Court’s three-factor test would be later used to deny parents the right to assistance of counsel in a custody hearing in Lassiter v. Dept. of Social Services.