Goldberg v. Kelly
Following is the case brief for Goldberg v. Kelly, 397 U.S. 254 (1970).
Case Summary of Goldberg v. Kelly:
- Welfare recipients sued in federal court because benefits were being terminated without recipients getting notice or a hearing prior to termination.
- The District Court held that a pre-termination hearing is required to satisfy procedural due process.
- On appeal, the Supreme Court agreed. The Court held that the Due Process Clause of the Fourteenth Amendment is violated when a State terminates welfare benefits without giving the beneficiary notice and an opportunity to be heard prior to termination.
Goldberg v. Kelly Case Brief
Statement of the Facts:
Appellees — residents of New York City who received federal aid through the Aid to Families with Dependent Children program or New York State’s Home Relief program — brought suit in Federal District Court. They alleged that the welfare officials who administered those programs terminated, or were about to terminate, appellees from aid without prior notice or a hearing, in violation of due process.
At the time the suit was filed, welfare officials did not provide notice or a hearing prior to the termination of benefits. However, the rules were amended during the suit to allow for an informal pre-termination review and post-termination hearing.
- Appellees filed suit in the District Court for the Southern District of New York.
- The District Court found for Appellees, holding that a pre-termination evidentiary hearing is necessary to satisfy due process.
- The Commissioner of Social Services for the City of New York appealed.
- The Supreme Court took the appeal in order to resolve a disagreement with the District Court in the present case and the lower court decision in Wheeler v. Montgomery, which the Supreme Court also decided the same day, at 397 U.S. 280 (1970).
Issue and Holding:
Does a State that terminates someone’s welfare assistance without allowing an evidentiary hearing prior to termination violate the Due Process Clause of the Fourteenth Amendment? Yes.
The decision of the District Court for the Southern District of New York is affirmed.
Rule of Law or Legal Principle Applied:
Procedural due process under the Fourteenth Amendment’s Due Process Clause demands that a welfare recipient be allowed an evidentiary hearing before welfare benefits are terminated.
- A pre-termination hearing is required for procedural due process.
For people qualified to receive them, welfare benefits are not a privilege, but a statutory entitlement. Procedural due process is required before such entitlements are terminated. Further, the welfare recipient’s interest in receiving benefits (which provide essentials for basic living) coupled with the State’s interest in making sure eligible people receive those benefits uninterrupted, clearly outweighs the burden of ferreting out people who are improperly receiving welfare benefits.
Accordingly, a pre-termination hearing is required to ensure that welfare recipients are accorded procedural due process. The combination of an informal pre-termination review and a post-termination hearing does not suffice.
- The pre-termination hearing need not be a trial or quasi-trial.
The requirements of the pre-termination evidentiary hearing need not be trial-like or onerous. Rather, the hearing simply needs to provide (i) adequate notice, (ii) the chance for the welfare recipient to be heard and cross-examine adverse witnesses, (iii) an impartial decisionmaker, and (iv) a written decision based on the facts presented.
Dissenting Opinion – from companion case Wheeler v. Montgomery (Burger):
The Court is improperly legislating. A process is in place to give a hearing to welfare recipients, and that process should be allowed to function before the courts step in to find it unsatisfactory.
Dissenting Opinion (Black):
There are many people who are not qualified to receive welfare, but still receive it. The Court’s decision to require pre-termination hearings will slow down the process, making it difficult for governments to protect the welfare program’s funds.
Dissenting Opinion – from companion case Wheeler v. Montgomery (Stewart):
While it is a close case, the pre-termination review and post-termination hearing procedures set forth by the City of New York do not violate the Constitution.
Goldberg v. Kelly is significant because it gives parameters to the requirements of procedural due process in connection with statutory entitlements. By requiring an evidentiary process before benefits are taken away gives welfare beneficiaries a type of property interest in the benefits they receive.