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Mathews v. Eldridge

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
Seal of the United States Supreme Court
Argued October 6, 1975
Decided February 24, 1976
Full case nameF. David Mathews, Secretary of Health, Education, and Welfare, v. George H. Eldridge
Citations424 U.S. 319 (more)
96 S. Ct. 893; 47 L. Ed. 2d 18
Case history
PriorEldridge 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).
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 P. Stevens
Case opinions
MajorityPowell, joined by Burger, Stewart, White, Blackmun, Rehnquist
DissentBrennan, joined by Marshall
Stevens took no part in the consideration or decision of the case.
Laws applied
U.S. Const. amend. V

Legal principlesEdit

Determining the constitutional sufficiency of administrative procedures, prior to the initial termination of benefits and pending review, requires consideration of three factors:

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

FactsEdit

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.

See alsoEdit

External linksEdit