Facts of the case
George Eldridge, who had originally been deemed disabled due to chronic anxiety and back strain, was informed by letter that his disability status was ending and that his benefits would be terminated. Social Security Administration procedures provided for ample notification and an evidentiary hearing before a final determination was made, but Eldridge’s benefits were cut off until that hearing could take place. Eldridge challenged the termination of his benefits without such a hearing.
Why is the case important?
Respondent Eldridge commenced this action in District Court to challenge the constitutional validity of the administrative procedures established by the Secretary of Health Education and Welfare for establishing whether there exists a continuing disability entitling a recipient to Social Security Disability (SSD) benefits. Eldridge was notified his benefits would terminate without an opportunity for a prior hearing.
Does due process require a pretermination hearing prior to discontinuing SSD benefits?
No. Reversed. The Court distinguished Goldberg, saying the crucial factor there was that welfare recipients are in dire need, and assistance is only given to persons on the very margin of subsistence whereas eligibility for SSD is not based on financial need. An additional factor is the fairness and reliability of existing pretermination procedures, and the probable value of additional procedural safeguards. The decision whether to discontinue SSD benefits will turn, in most cases, on routine, unbiased medical reports. Finally, Goldberg was in part based on the Court’s conclusion that written submissions were an inadequate substitute for oral presentation by welfare recipients whereas the detailed SSD questionnaires were sufficient. Dissent. To say that the discontinuance of disability benefits may cause the recipient to suffer only a limited deprivation is speculative and no argument. The very legislative determination to provide SSD benefits, without any predetermination of need, presumes a need which is not this Court’s function to denigrate. Concurrence. None.
The United States Supreme Court found that respondent had not been denied procedural due process when he was not granted an evidentiary hearing prior to termination of his Social Security disability benefit payments. The district court had jurisdiction over the suit, because respondent had presented his claims for review to both the district social security office and the regional office for reconsideration, and petitioner Secretary of Health, Education, and Welfare had accepted the termination through the Social Security Administration. Procedural due process had been satisfied because respondent was not in as dire a position as that of a typical welfare recipient, and because of the myriad procedural safeguards of the process, including an evidentiary hearing before the denial of the claim became final. The public interest in limiting the procedures available was significant, given the cost of additional procedures.
- Advocates: Donald E. Earls Argued the cause for the respondent Robert H. Bork Argued the cause for the petitioner
- Petitioner: Mathews
- Respondent: Eldridge
- DECIDED BY:Burger Court
- Location: United States Department of Health, Education, and Welfare: Social Security Division
|Citation:||424 US 319 (1976)|
|Argued:||Oct 6, 1975|
|Decided:||Feb 24, 1976|