Mathews v. Eldridge
 | This article needs additional citations for verification. (December 2007) |
| Mathews v. Eldridge | |
|---|---|
 | |
| 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 |
| Case history | |
| Prior | 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, that the termination of those benefits implicates due process, but that the termination of Social Security benefits does not require a pre-termination hearing. The case is important in the development of American administrative law.
Legal principles
In determining the amount of process due, the court should weigh three factors:
- The interests of the individual in retaining their property, and the injury threatened by the official action
- The risk of error through the procedures used and probable value, if any, of additional or substitute procedural safeguards;
- 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 implicating due process.
Termination of social security benefits does not require a pre-termination hearing.
Facts and procedural posture
The SSA terminated Eldridge's social security benefits through 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, holding that no pre-termination hearing was required.