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Keywords

hearingdue processrespondent
hearingwilldue processrespondentcredibility

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Mathews v. Eldridge, 424 U.S. 319, 96 S.Ct. 893, 47 L.Ed.2d 18

Facts

Respondent Eldridge was awarded disability benefits in June 1968. In March 1972, he completed a questionnaire from the state agency monitoring his condition, asserting that his disability had not improved. The agency tentatively determined that his disability had ceased in May 1972, and after a final determination reaffirming this, the Social Security Administration notified him that his benefits would terminate. Instead of seeking reconsideration, Eldridge filed an action challenging the constitutionality of the termination procedures.

A few years after respondent was first awarded disability benefits he received and completed a questionnaire from the monitoring state agency.

Issue

Whether the Due Process Clause of the Fifth Amendment requires that prior to the termination of Social Security disability benefit payments, the recipient be afforded an opportunity for an evidentiary hearing.

The issue in this case is whether the Due Process Clause of the Fifth Amendment requires that prior to the termination of Social Security disability benefit payments the recipient be afforded an opportunity for an evidentiary hearing.

Rule

An evidentiary hearing is not required prior to the termination of Social Security disability payments, and the administrative procedures prescribed under the Act fully comport with due process.

An evidentiary hearing is not required prior to the termination of Social Security disability payments and the administrative procedures prescribed under the Act fully comport with due process.

Analysis

The Supreme Court analyzed the existing administrative procedures and determined that they provided sufficient due process protections. The Court considered the private interest affected, the risk of erroneous deprivation, and the government's interest in maintaining efficient administrative processes. It concluded that the procedures in place, including the opportunity for written submissions and access to evidence, were adequate to protect the recipient's rights without necessitating a formal evidentiary hearing.

The private interest that will be adversely affected by an erroneous termination of benefits is likely to be less in the case of a disabled worker than in the case of a welfare recipient, like the claimants in Goldberg, supra.

Conclusion

The Supreme Court reversed the lower court's decision, holding that the administrative procedures for terminating disability benefits were constitutional and did not require an evidentiary hearing.

493 F.2d 1230, reversed.

Who won?

The Secretary of Health, Education and Welfare prevailed because the Supreme Court found that the existing administrative procedures were sufficient to meet due process requirements.

The Secretary contended that Goldberg was not controlling since eligibility for disability benefits, unlike eligibility for welfare benefits, is not based on financial need and since issues of credibility and veracity do not play a significant role in the disability entitlement decision, which turns primarily on medical evidence.

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