Goldberg v. Kelly

John Kelly, acting on behalf of New York residents receiving financial assistance either under the federally-assisted program for Families with Dependent Children or under New York State’s home relief program, challenged the constitutionality of procedures for notice and termination of such aid. Although originally offering no official notice or opportunity for hearings to those whose aid was scheduled for termination, the State of New York implemented a hearing procedure after commencement of Kelly’s litigation.

Rule:

The fundamental requisite of due process of law is the opportunity to be heard. The hearing must be at a meaningful time and in a meaningful manner. These principles require that a recipient have timely and adequate notice detailing the reasons for a proposed termination, and an effective opportunity to defend by confronting any adverse witnesses and by presenting his own arguments and evidence orally. These rights are important in cases where recipients have challenged proposed terminations as resting on incorrect or misleading factual premises or on misapplication of rules or policies to the facts of particular cases.

Brief Fact Summary:

Appellees were financial aid recipients whose benefits were terminated without being afforded a pre-termination hearing, which they challenged as a denial of due process.

Case Commentary:

In determining the level of significance that should be accorded to receiving welfare benefits, the Court sought to liken it to other rights that it had found to be valid. These included the rights to unemployment insurance and tax exemptions. However, despite this attempt to analogize to precedent, many observers viewed the decision as an unusually bold step by an institution known for its caution. As some of the dissents pointed out, this decision actually could hinder the pursuit of financial assistance by indigent recipients. The extensive process envisioned by Brennan would take more time to unfold than the more informal evaluation that the agency had used, so benefits might not be reinstated for longer. It was also more likely that benefits would be erroneously paid, since the agency would have less motivation to go through pre-termination procedures unless it was confident that a recipient had become ineligible. This would deplete the pool of money available to deserving recipients. However, the majority’s ruling has not been disturbed or significantly challenged, and welfare benefits are firmly established as a form of property requiring the application of due process before deprivation. Brennan later wrote that Goldberg was the most important opinion that he authored as a Justice of the Supreme Court, and it remains the foundation of procedural due process.