Mathews v. Eldridge

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Mathews v. Eldridge
Supreme Court of the United States
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: 424 U.S. 319; 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
Chief Justice: Warren E. Burger
Associate Justices: William J. Brennan, Jr., Potter Stewart, Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist, John Paul Stevens
Case opinions
Majority by: Powell
Joined by: Burger, Stewart, White, Blackmun, Rehnquist
Dissent by: Brennan
Joined by: Marshall
Stevens took no part in the consideration or decision of the case.
Laws applied
U.S. Const. amend. XIV

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, that the termination of those benefits implicates due process, but that the termination of Social Security benefits does not require a pre-termination hearing. The case is important in the development of American administrative law.

[edit] Legal principles

In determining the amount of process due, the court should weigh three factors:

  1. The interests of the individual in retaining their property, and the injury threatened by the official action
  2. The costs and administrative burden of the additional process, and the interests of the government in efficient adjudication
  3. The risk of error through the procedures used and probable value, if any, of additional or substitute procedural safeguards;

Social security benefits are a statutorily created property right implicating due process.

Termination of social security benefits does not require a pre-termination hearing.

[edit] Facts and procedural posture

The SSA terminated Eldridge's social security benefits through 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, holding that no pre-termination hearing was required.

[edit] See also