End date 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 Prior history Grant of certiorari from the United States Court of Appeals, 492 F.2d 1230 Majority Powell, joined by Burger, Stewart, White, Blackmun, Rehnquist Dissent Brennan, joined by Marshall Ruling court Supreme Court of the United States Similar Goldberg v Kelly, Citizens to Preserve Overton P, Goss v Lopez, Hamdi v Rumsfeld | ||
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, and the termination of such benefits implicates due process but does not require a pre-termination hearing. The case is significant in the development of American administrative law.
Contents
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 and so implicate due process.
Termination of such benefits does not require a pre-termination hearing.
Facts
The Social Security Administration terminated Eldridge's benefits by 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 and held that pre-termination hearing was not required.