Mathews v. Eldridge

Following is the case brief for Mathews v. Eldridge, 424 U.S. 319 (1976)

Case Summary of Mathews v. Eldridge:

  • Respondent Eldridge, who was receiving Social Security disability benefits, was notified that his disability benefits would be terminated based on his answers to a questionnaire and his medical records.
  • Eldridge then sued in federal court, alleging that due process requires an evidentiary hearing before benefits could be terminated.
  • The District Court and Court of Appeals agreed with Eldridge.
  • The U.S. Supreme Court, however, reversed.  It held that due process does not require an evidentiary hearing before terminating disability benefits, given that other procedural protections are in place.

Mathews v. Eldridge Case Brief

Statement of the Facts:

In 1968, respondent Eldridge was awarded Social Security disability benefits for a work-related injury.  Four years later, a state agency reviewed information from Eldridge’s physicians and a questionnaire filled out by Eldridge.  The agency then concluded that Eldridge’s disability benefits would be terminated.

Eldridge was offered the right to seek reconsideration of the decision.  However, Eldridge decided to sue in federal court instead, challenging the constitutional validity of the Social Security disability procedures.  Specifically, he alleged that due process requires a pre-termination hearing, based on the Court’s decision in Goldberg v. Kelly, 397 U.S. 254 (1970), which required an evidentiary hearing before terminating welfare benefits.

Procedural History:

  • The District Court agreed with Eldridge, finding that due process required a pre-termination hearing based on Goldberg v. Kelly.
  • The Fourth Circuit Court of Appeals affirmed.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does the Due Process Clause of the Fifth Amendment require an evidentiary hearing before Social Security disability benefits are terminated?  No.

Judgment:

The decision of the Fourth Circuit Court of Appeals is reversed.

Rule of Law or Legal Principle Applied:

Due process is a flexible concept and the procedural protections are based upon what the situation demands.

Reasoning:

As a threshold matter, Eldridge’s lawsuit was appropriate because, even though he did not exhaust all possible administrative avenues before instituting a lawsuit, his interest in having a particular issue promptly resolved is so great that the administrative agency is not given deference.

Due process is a flexible concept such that the required procedural protections vary based upon the situation.  To determine the constitutional sufficiency of an administrative procedure, the Court must look to (i) the private interest at issue; (ii) the risk of an erroneous deprivation of that interest; and (iii) the government’s interest, including the cost of additional process.

In this case, the loss of disability benefits is less of a burden than the loss of welfare benefits.  Thus, Goldberg is not controlling in this case.  Further, the decision regarding disability benefits will normally turn on routine, unbiased medical reports, and thus an evidentiary hearing has less value than in the welfare context.  Also, there are many procedural protections already in place – the questionnaire, medical records, and access to the information on which the state relied – to ensure due process.  Requiring an evidentiary hearing for every termination case would be too much of an administrative burden on the government.

Concurring and Dissenting Opinions:

Dissenting Opinion (Brennan):

An evidentiary hearing, similar to the one required for welfare beneficiaries is appropriate in this case.  The notion that terminating disability benefits is only a limited deprivation is speculation.  Eldridge suffered serious financial difficulty as a result of the state’s decision to terminate benefits.

Significance:

Mathews v. Eldridge recognized that Social Security disability benefits can be claimed as a property right that is worth constitutional protection.  However, an evidentiary hearing prior to the termination of benefits is not required by the Fifth Amendment’s Due Process Clause.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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