Mathews v. Eldridge

Brief Fact Summary. The Respondent, Eldridge (Respondent), was a disabled worker who had been receiving Social Security benefits. After a case review by the state agency responsible for monitoring his medical condition, the Respondent’s benefits were terminated without a hearing.

Synopsis of Rule of Law. The appropriateness and scope of a prior evidentiary hearing is determined by balancing 3 factors: (1) the private interest that will be affected; (2) the risk of mistakenly depriving an individual of his interest and (3) the value of instituting additional or substitute safeguards.

Facts. The Respondent had been receiving federal disability coverage for several years when a state agency reviewed his medical condition. After reviewing his medical records and obtaining a psychiatric consult, the agency determined that the Respondent was no longer disabled. The agency wrote the Respondent a letter, explaining its findings and providing an opportunity for the Respondent to request time to provide additional information to prove his disability. But, after the Respondent refused to provide additional information, the agency made its final determination, which was accepted by the Social Security Administration. This led to the termination of his Social Security disability benefit.

Issue. Is it a violation of the Due Process clause to discontinue a recipient’s Social Security disability benefits without holding an evidentiary hearing?

Held. No. An evidentiary hearing is not required prior to the termination of disability benefits. The present administrative procedures fully comply with the requirements of the Due Process Clause.

Dissent. Prior to terminating benefits, a governmental agency must afford an evidentiary hearing.

Discussion. This case is different than the welfare case, Goldberg, because the level of disability is something that can be ascertained through the use of expert medical opinion and written reports. Therefore, the value of an evidentiary hearing is greatly diminished. Furthermore, before a final ruling was made the Respondent had the opportunity to see the results, all reports relied upon, and provide additional proof of disabi