Mathews v. Eldridge

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 have diabetes. A few years later, Eldridge filled out a questionnaire from the state agency that monitored the benefits. The agency also obtained reports from Eldridge's doctor and an independent medical consultant. The agency wrote to Eldridge 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 that he 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 benefits were 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 entitled to an evidentiary hearing. The court based this decision in part on Goldberg v. Kelly (1970). In that case, it was decided that a welfare recipient was entitled to a hearing prior to the termination of payments. The court of appeals agreed with the district court.