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
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 (more) 96 S. Ct. 893; 47 L. Ed. 2d 18
Case history
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).
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
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

Legal principles

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.^[1]

The Court determined that Social Security benefits are a statutorily-created property right and so implicate due process.^[2]

However, after balancing the three factors, the Court ruled that the administrative procedures in place were constitutional and held that termination of Social Security benefits does not require a pre-termination hearing. See Mathews v. Eldridge, 424 U.S. 319, 347-49 (1976).

Background

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.

Decision

The Supreme Court reversed and held that pre-termination hearing was not required.

See also

• List of United States Supreme Court cases, volume 424
• Goldberg v. Kelly (1970)