Mathews v. Eldridge

Brief Fact Summary.

Respondent Eldridge challenged the constitutional validity of the administrative procedures established by the Secretary of Health, Education, and Welfare for assessing whether there exists a continuing disability.

Synopsis of Rule of Law.

Procedural due process imposes constraints on governmental decisions which deprive individuals of liberty or property interests within the meaning of the Due Process of the Fifth Amendment.

Facts.

Respondent Eldridge was first awarded benefits in 1968. In 1972, he received a questionnaire from the state agency charged with monitoring his medical condition. Eldridge completed the questionnaire, indicating that his condition had not improved and identifying the medical sources, including physicians, from whom he had received treatment recently. The state agency then obtained reports from his physician and a psychiatric consultant. After considering these reports and other information the agency informed Eldridge that it had made a tentative determination that his disability had ceased in May 1972. The Social Security Administration notified Eldridge that his benefits would terminate soon and advised him of his right to seek reconsideration by the state agency of his initial determination.

Issue.

Does the Due Process Clause of the Fifth Amendment require that prior to the termination of Social Security disability benefit payments the recipient be afforded an opportunity for an evidentiary hearing?

Held.

No, the government and public interests outweigh the recipient’s interests. Moreover, 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. Consequently, the Due Process Clause of the Fifth Amendment does not require that prior to the termination of Social Security disability benefit payments the recipient be afforded an opportunity for an evidentiary hearing.

Dissent.

Justice Brennan

Prior to termination of benefits, Eldridge must be afforded an evidentiary hearing of the type required for welfare beneficiaries. The Court’s consideration that a discontinuance of disability benefits may cause the recipient to suffer only a limited deprivation is no argument as it is speculative. Also, the legislative determination to provide disability benefits, without any prerequisite determination of need presumes a need by the recipient which is not this Court’s function to denigrate. Finally, that a worker, who had been placed in the untenable position of having been denied disability benefits, may still seek other forms of public assistance, is no argument.

Discussion.

Moreover, the disabled worker’s need is likely to be less than that of a welfare recipient. 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 or his family below the subsistence level. In view of these potential sources of temporary income, there is no reason to depart from the ordinary principle that something less than an evidentiary hearing is sufficient prior to adverse administrative action. Opportunity is also afforded to 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. These procedures enable the recipient to mold his argument to respond to the precise issues which the decisionmaker regards as crucial. Finally, the administrative burden and other societal costs that would be associated with requiring an evidentiary hearing upon demand in all cases prior to the termination of disability benefits would not be insubstantial.