Mathews v. Eldridge
Citation: 424 U.S. 319 (U.S. Supreme Court, 1976)
Facts
George Eldridge received Social Security disability benefits. The Social Security Administration determined that his disability had ceased and terminated his benefits without providing a pre-termination evidentiary hearing. Eldridge was afforded written notice and an opportunity to submit written evidence before termination, and could obtain a full evidentiary hearing after termination. Eldridge challenged the termination procedure as a denial of due process under Goldberg v. Kelly.
Issue
Does due process require a pre-termination evidentiary hearing before the government terminates Social Security disability benefits?
Holding
The Supreme Court held, 6-2, that no pre-termination hearing was required. The written procedures provided — notice, opportunity to submit documentary evidence, and a post-termination hearing — satisfied due process. The Court declined to extend Goldberg v. Kelly’s pre-termination hearing requirement to disability benefits.
Rule
The procedural due process required before the government deprives a person of a protected interest is determined by balancing three factors: (1) the private interest affected by the official action; (2) the risk of erroneous deprivation through the procedures used and the probable value of additional procedures; and (3) the government’s interest, including the administrative and fiscal burdens of additional procedures. No category of benefits categorically requires a pre-termination hearing; the appropriate process depends on context.
Significance
Mathews v. Eldridge establishes the universal balancing test for procedural due process that governs all modern due process analysis. It displaces any categorical rule requiring pre-termination hearings (limiting Goldberg v. Kelly to its facts) and places the procedural due process inquiry on a flexible, context-sensitive foundation. The three-factor Mathews balancing test is now the starting point for every procedural due process question in both constitutional and administrative law.