Mathews v. Eldridge
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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.
|Mathews v. Eldridge|
|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 (more)|
96 S. Ct. 893; 47 L. Ed. 2d 18
|Prior||Eldridge v. Weinberger, 361 F. Supp. 520 (W.D. Va. 1973), affirmed, 493 F.2d 1230 (4th Cir. 1974), cert. granted, 419 U.S. 1104 (1975).|
|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|
|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.|
|U.S. Const. amend. V|
Determining the constitutional sufficiency of administrative procedures, prior to the initial termination of benefits and pending review, requires consideration of 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.
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.