Mathews v. Eldridge

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Mathews v. Eldridge
Seal of the United States Supreme Court.svg
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
Prior history Grant of certiorari from the United States Court of Appeals, 492 F.2d 1230
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
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

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.

Legal principles[edit]

In determining the amount of process due, the court should weigh 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.

Social Security benefits are a statutorily-created property right and so implicate due process.

Termination of such benefits does not require a pre-termination hearing.

Facts[edit]

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.

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

See also[edit]

External links[edit]

  • Text of Mathews v. Eldridge, 424 U.S. 319 (1976) is available from:  Findlaw  Justia