This case was brought by residents of New York City who received financial aid under the federally assisted program of Aid to Families with Dependent Children (AFDC) or under New York State’s Home Relief Program. Their complaint alleged that City officials administering these programs terminated such aid without prior notice and hearing, denying them due process of law. After the suit was filed, the City adopted procedures for notice and hearing, which the plaintiff-appellees then challenged as constitutionally inadequate. The procedure allowed the recipient to challenge the proposed termination of benefits within seven days and submit a written statement for the reviewing official to make a final determination. Appellees’ challenged the procedures’ lack of an opportunity to personally appear before the reviewing officer for oral testimony and cross-examination of adverse witnesses. The procedure did allow for a post-termination “fair hearing,” however. The District Court held that only a pre-termination hearing would satisfy the constitutional due process requirement.
Does a state’s termination of public aid, without affording the beneficiary a hearing prior to termination, violate notions of procedural due process as set out in the Fourteenth Amendment’s Due Process Clause?
Yes. In a 5-to-3 decision, the Court held that states must afford public aid recipients a pre-termination evidentiary hearing before discontinuing their aid. Noting that welfare benefits are statutory entitlements, rather than privileges,” the Court weighed welfare recipients’ need for procedural due process against the competing considerations of the possible harm they might suffer from discontinuation and the government’s interest in summary adjudication. The Court concluded that state interests in conserving administrative costs are not sufficient to override public aid recipients’ interest in procedural due process. With respect to New York’s newly implemented hearings, the Court found them deficient insofar as they did not permit recipients to present evidence, be heard orally in person or through counsel, or cross-examine adverse witnesses.”
The interest of the eligible recipient in uninterrupted receipt of public assistance, coupled with the State’s interest that payments not be erroneously terminated, clearly outweigh the State’s competing interest to prevent administrative and fiscal burdens. The pre-termination hearing need not take the form of a judicial or quasi- judicial trial, as the “fair hearing” will afford full administrative review later on. It need only produce an initial determination that the welfare’s grounds for termination of benefits are valid.
Manhattan Municipal Building
397 US 254 (1970)
Oct 13, 1969
Mar 23, 1970