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Mathews v. Eldridge

Supreme Court of the United States · 1976 · Constitutional Law

procedural due processbalancing testprivate interestrisk of errorDue Process ClauseFifth AmendmentSocial Security disability benefitspretermination hearing

Facts

Eldridge had been receiving Social Security disability benefits since 1968. In 1972, after a questionnaire review and collection of medical reports from his physician and a psychiatric consultant, the state agency made a tentative determination that his disability had ceased, informed him of the reasons, and invited him to submit additional written information. Eldridge responded in writing, disputing part of the agency's characterization of his condition, but the agency made a final determination that he was no longer disabled, the SSA accepted that determination, and his benefits were terminated. Instead of seeking reconsideration through the agency's full administrative review process, Eldridge filed suit claiming the Fifth Amendment required an evidentiary hearing before termination.

Issue

Does the Due Process Clause of the Fifth Amendment require the government to provide an evidentiary hearing before terminating Social Security disability benefit payments? Also, was Eldridge's claim sufficiently final under 42 U.S.C. § 405(g) to permit judicial review of his constitutional challenge?

Rule

Identification of the specific dictates of procedural due process generally requires consideration of three factors: first, the private interest affected by the official action; second, the risk of an erroneous deprivation through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and third, the Government's interest, including the function involved and the fiscal and administrative burdens that additional or substitute procedures would entail. Due process is flexible and requires procedural protections tailored to the circumstances rather than a judicial-type evidentiary hearing in every case.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, the federal administrator of a disability-income program mails Lena Ortiz a notice stating that her benefits will end in 60 days because updated reports from her neurologist and an independent physician indicate improvement. The notice summarizes the medical basis for the proposed termination, allows her representative to inspect the file, invites written submissions, and provides a full evidentiary hearing only after termination if she seeks reconsideration and loses.

Lena sues, arguing that due process always requires an oral evidentiary hearing before disability payments can be stopped. How should a court most likely rule?

Explanation. The governing rule is that due process is flexible and generally requires balancing three factors: the private interest affected, the risk of erroneous deprivation and the likely value of additional safeguards, and the government's interest including fiscal and administrative burdens. Disability benefits are a protected property interest, but the majority held that notice, explanation of reasons, access through a representative to the evidence, written rebuttal, and full post-termination review can satisfy due process without a pretermination evidentiary hearing, especially where the decision largely turns on written medical evidence.