Mathews v. Eldridge

Petitioner
Forrest D. Mathews, U.S. Secretary of Health, Education, and Welfare
Respondent
George Eldridge
Petitioner's Claim
That an evidentiary hearing prior to the termination of Social Security disability benefits is not a requirement of due process.
Chief Lawyer for Petitioner
Robert H. Bork, U.S. Solicitor General
Chief Lawyer for Respondent
Donald E. Earles
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr. (writing for the Court), William H. Rehnquist, Potter Stewart, Byron R. White,
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall (John Paul Stevens did not participate)
Place
Washington, D.C.
Date of Decision
24 February 1976
Decision
The lack of an evidentiary hearing prior to cutting off George Eldridge's disability benefits did not violate the Due Process Clause of the Fifth Amendment.
Significance
Mathews v. Eldridge established the basic test for deciding if a particular procedure satisfied the demands of due process. The Court also noted that due process was flexible.
George Eldridge began receiving Social Security disability benefits in June of 1968 because of chronic anxiety and back strain. He was later found to havediabetes. A few years later, Eldridge filled out a questionnaire from the state agency that monitored the benefits. The agency also obtained reports fromEldridge's doctor and an independent medical consultant. The agency wrote toEldridge that it had tentatively decided that his disability had ceased in May 1972. In his reply letter, Eldridge noted that he had arthritis of the spine, not a strained back, and that he felt the agency had enough information to establish his disability. The agency reaffirmed its tentative decision. This decision was accepted by the Social Security Administration (SSA), which notified Eldridge in July that his benefits would end after that month and thathe had a right to reconsideration by the state agency within six months. Eldridge did not request reconsideration, but instead brought his case to the district court, challenging the constitutionality of the termination of his benefits. He felt that not receiving an evidentiary hearing before his benefitswere cut off violated his right to due process in accordance with the Fifth Amendment. Eldridge sought the reinstatement of his benefits pending a hearing.
The district court decided that the termination violated procedural due process. It held that prior to the termination of benefits, Eldridge was entitledto an evidentiary hearing. The court based this decision in part on Goldberg v. Kelly (1970). In that case, it was decided that a welfare recipientwas entitled to a hearing prior to the termination of payments. The court ofappeals agreed with the district court.
Due Process is Flexible
The secretary of health, education, and welfare contended that the district court should not have heard the case because district courts do not have jurisdiction over an action seeking the review of the secretary. District courts can only review a final decision of the secretary. The secretary based his claim on Weinberger v. Salfi (1975). In that case, the Supreme Court decided that judicial review in an action challenging the denial of claimed benefits was possible only after exhausting all of the administrative remedies, including a final decision by the secretary. When Mathews v. Eldridge was brought before the Supreme Court, however, it held that in the instant case, Eldridge satisfied the requirement that a claim must be presented to the secretary by filling out the questionnaire and writing a letter to the state agency. Although Eldridge did not exhaust the secretary's internal review procedures, the denial of his claim was enough of a "final decision" to satisfy the exhaustion requirement. Thus Eldridge had the right to present the case tothe district court.
The Fifth Amendment states that no person shall "be deprived of life, liberty, or property without due process of law." The secretary contended that the existing administrative procedures provided all the process that is constitutionally due before someone can be deprived of benefits. Eldridge contended that the existing review procedures would be adequate if the disability benefitswere terminated after the evidentiary hearing, not before it. Justice Powell, writing for the majority, quoted Cafeteria Workers v. McElroy (1961)"Due process, unlike some legal rules, is not a technical conception with afixed content unrelated to time, place and circumstances." Powell also quotedMorrissey v. Brewer (1972), "Due process is flexible, and calls for such procedural protections as the particular situation demands." Powell listed the three factors that must be considered when looking into the specific dictates of due process: 1) the private interest that the official action willaffect; 2) the risk of mistakenly depriving someone of benefits, and the probable value of additional procedural safeguards; 3) the Government's interest,including the financial and administrative costs that additional procedureswould bring about.
Powell described the procedures in place for terminating Social Security disability benefits. The disability insurance program is jointly administered bystate and federal agencies. State agencies determine if a person has a disability, when it began, and when it ceased. The worker must show, using medicaltests, that he cannot work. The main reason for terminating someone's benefits is that the worker is no longer disabled or has returned to work. A team determines if a person continues to be eligible for benefits. The team consistsof a doctor and a nonmedical person trained in disability evaluation. The agency asks the worker, through questionnaires, about his current condition, treatments, and restrictions. The agency also gets information from the worker's doctor. If the agency and the beneficiary disagree about his condition, theagency informs him that his benefits may be terminated, provides a summary of the evidence, and offers the opportunity to review the medical reports andother evidence in his file. He may also respond in writing and send in additional evidence. At that point, the state agency makes its final decision, which is reviewed by an examiner from the SSA Bureau of Disability Insurance. TheSSA then notifies the recipient of the decision and the reasons for it and tells him that he has the right to seek reconsideration from the state agency.The benefits end two months after the person's recovery has taken place. Ifthe person seeks reconsideration from the state agency, and the determinationgoes against him, the SSA reviews the decision. The person then has a rightto an evidentiary hearing in front of an SSA administrative law judge. Afterthat, the claimant is entitled to request discretionary review by the SSA Appeals Council. Finally, he may obtain a judicial review.
Powell noted that despite the elaborate procedures provided, the district court and court of appeals considered them to be constitutionally inadequate. Those courts concluded that due process required an evidentiary hearing beforethe benefits were terminated. Powell disagreed with that conclusion, believing that a hearing after termination of benefits was sufficient. Powell reasoned that disability benefits were not based on financial need. "Indeed, it is wholly unrelated to the worker's income or support from many other sources."
The Court recognized that the length of time a person is wrongfully deprivedof benefits is important in assessing the impact of the government's action on the person's interests. The secretary conceded that the delay between the cutoff of benefits and the final decision after a hearing is over one year. Powell noted that "the hardship imposed upon the erroneously terminated disability recipient may be significant. Still the disabled worker's need is likelyto be less than that of a welfare recipient. In addition to the possibility of access to private resources, other forms of government assistance will become available" if the worker falls below the subsistence level. Something lessthan an evidentiary hearing is sufficient prior to terminating disability benefits.
Powell pointed out that a medical assessment is a more sharply focused and easily documented decision than one involving the termination of welfare benefits. It is based on routine, standard, and unbiased medical reports by specialists. The disability benefits entitlement assessment provides an effective means for the recipient to communicate to the decision-maker, mainly by way ofthe questionnaire. Also, before the termination of benefits, the person is given full access to the information relied on by the state agency.
Powell noted that the administrative burden must be weighed against requiring, as a constitutional right, an evidentiary hearing upon demand in all casesprior to the termination of disability benefits. "The ultimate additional cost in terms of money and administrative burden would not be insubstantial." Healso noted that the judicial model of an evidentiary hearing is neither a required, nor even the most effective, method of decision making in every circumstance. The essence of due process is that a person facing a serious loss begiven notice of the case and the opportunity to present his side of it. Theprocedures must be tailored to the capacities and circumstances of the personto make sure he or she has a meaningful opportunity to present his case. Indetermining what process is due in this case, substantial weight must be given to the good faith judgments of the people who work in the administration ofsocial welfare programs. The prescribed procedures provide the claimant withan effective process for asserting his or her claim prior to any administrative action. The claimant is also assured a right to an evidentiary hearing and subsequent judicial review before the denial of his claim becomes final.
Powell summed up his opinion by stating that an evidentiary hearing is not required before disability benefits are ended. The current administrative procedures "fully comport with due process."
Hearing Should Come Before Termination of Benefits
Justices Brennan and Marshall dissented. Brennan felt that Eldridge must be given an evidentiary hearing of the type required for welfare recipients. He noted that since disability benefits are provided without a determination of need, a need is presumed. In this case, because disability benefits were terminated, the Eldridge home was foreclosed on and the family's furniture was repossessed, forcing everyone to sleep in one bed. "Finally, it is also no argument that a worker, who has been placed in the untenable position of having been denied disability benefits may still seek other forms of public assistance."
Impact
Mathews v. Eldridge was often quoted in later opinions regarding the definition of due process. Powell's three factors for resolving the issue involving the constitutional sufficiency of administrative procedures before theinitial termination of benefits have been relied on in other cases of this sort.
Cases challenging the termination of benefits have tried to rely on Mathews v. Eldridge. They have cited this case when desiring judicial review. This case differed from many others in that it dealt with a constitutional issue. In Califano v. Sanders (1977) the Supreme Court noted that a decision denying judicial jurisdiction in Eldridge would effectively have closed the federal forum to the adjudication of reasonable constitutional claims. Thus Eldridge merely adhered to the well-established principle that when constitutional questions are in issue, the availability of judicial review is presumed.
Related Cases

• Cafeteria Workers v. McElroy, 367 U.S. 886 (1961).
  
• Goldberg v. Kelly, 397 U.S. 254 (1970).
  
• Richardson v. Perales, 402 U.S. 389 (1971).
  
• Morrissey v. Brewer, 408 U.S. 471 (1972).
  
• Weinberger v. Salfi, 422 U.S. 749 (1975).
  
• Califano v. Sanders, 430 U.S. 199 (1977).