Mathews v. Eldridge
Mathews v. Eldridge | |||||||
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Argued October 6, 1975 Decided February 24, 1976 | |||||||
Full case name | F. David Mathews, Secretary of Health, Education, and Welfare, v. George H. Eldridge | ||||||
Citations |
96 S.Ct. 893; 47 L.Ed.2d 18 | ||||||
Prior history | Grant of certiorari from the United States Court of Appeals, 492 F.2d 1230 | ||||||
Holding | |||||||
Due process does not require a Goldberg-type hearing prior to the termination of social security disability benefits on the ground that the worker is no longer disabled | |||||||
Court membership | |||||||
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Case opinions | |||||||
Majority | Powell, joined by Burger, Stewart, White, Blackmun, Rehnquist | ||||||
Dissent | Brennan, joined by Marshall | ||||||
Stevens took no part in the consideration or decision of the case. | |||||||
Laws applied | |||||||
U.S. Const. amend. V |
Mathews v. Eldridge, 424 U.S. 319 (1976), is a case in which the United States Supreme Court held that individuals have a statutorily granted property right in Social Security benefits, and the termination of such benefits implicates due process but does not require a pre-termination hearing. The case is significant in the development of American administrative law.
Legal principles
In determining the amount of process due, the court should weigh three factors:
- The interests of the individual in retaining their property and the injury threatened by the official action;
- The risk of error through the procedures used and probable value, if any, of additional or substitute procedural safeguards;
- The costs and administrative burden of the additional process, and the interests of the government in efficient adjudication.
Social Security benefits are a statutorily-created property right and so implicate due process.
Termination of such benefits does not require a pre-termination hearing.
Facts
The Social Security Administration terminated Eldridge's benefits by its normal procedures. However, Eldridge was not provided with a hearing before the termination of his benefits in which he could argue for a continuation of the benefits. He sued even though he had not exhausted his post-termination administrative remedies. The district court held that the termination was unconstitutional, and the court of appeals affirmed.
The Supreme Court reversed and held that pre-termination hearing was not required.