Mathews v. Eldridge

Brief Fact Summary.

The respondent challenged the constitutionality of the administrative procedures, which offered him no opportunity for an evidentiary hearing after his disability benefit was terminated by the state agency.

Synopsis of Rule of Law.

Identification of the specific dictates of due process requires consideration of three distinct factors: the private interest that will be affected by the official action; the risk of an erroneous deprivation of such interest through the procedures used; the Government’s interest.

Facts.

Cash benefits are provided to workers during periods in which they are completely disabled under the disability insurance benefits program created by the Social Security Act. Respondent Eldridge was first awarded benefits in June 1968. In March 1972, he received a questionnaire from the state agency charged with monitoring his medical condition. He completed the questionnaire, indicating that his condition had not improved. The state agency then obtained reports from his physician and informed Eldridge that it decided to terminate his disability benefits in 1972. Instead of requesting reconsideration Eldridge commended this action challenging the constitutional validity of the administrative procedures established.

Issue.

Does the due process requires that prior to the termination of Social Security disability benefit payments the recipient be afforded an opportunity for an evidentiary hearing?

Held.

No, because the government interests outweigh the recipient’s interests here. Also, the judicial model of an evidentiary hearing is neither a required nor even the most effective method of decisionmaking in all circumstances. The essence of due process is the requirement that a person in jeopardy of serious loss be given notice of the case against him and opportunity to meet it. All that is necessary is that the procedures be tailored, in light of the decision to be made to the circumstances of those who are to be heard to ensure that they are given a meaningful opportunity to present their case.

Discussion.

In assessing what process is due, substantial weight must be given to the good-faith judgments of the individuals charged by Congress with the administration of social welfare programs that the procedures they have provided assure fair consideration of the entitlement claims of individuals. This is especially so where, as here, the prescribed procedures not only provide the claimant with an effective process for asserting his claim prior to any administrative action, but also to assure a right to an evidentiary hearing, as well as to subsequent judicial review. Moreover, a recipient whose benefits are terminated is awarded full retroactive relief if he ultimately prevails, and thus his sole interest is in the uninterrupted receipt of this source of income. Eligibility for disability benefits is wholly unrelated to the worker’s income or support from many other sources and the potential deprivation here is generally likely to be not much. Therefore, an evidentiary hearing is not required prior to the termination of disability benefits and the present administrative procedures fully comport with due process.