Sunday, March 25, 2012

Mathews v. Eldridge case brief, 424 U.S. 319 (1976)

Mathews v. Eldridge
424 U.S. 319 (1976)

-Worker notified by mail that state planning to terminate disability benefits. Worker contended that his failure to have a pre-termination hearing violated his DP rights.
-Court said that the “fundamental requirement of due process is the opportunity to be heard ‘at a meaningful time and in a meaningful manner’”. This case deals with what process was due.

-Three elements of balancing test:
(1) How important was the liberty or property interest at stake?
-The court thought disability payments of lesser importance than welfare payments. The private interest that will be affected by the action—length of deprivation of benefits.
(2) The extent to which the requested procedure was likely or not to reduce an erroneous decision.   
-What was the likelihood of the agency making the wrong decision? Court said disability payments had to do w/doctor’s reports, etc. 
-Risk of erroneous deprivation of such interest through procedures used and probable value of add’l procedural safeguards; fairness and reliability of existing pre-termination procedures.

(3)  The likelihood or not of additional procedure improving the decision against how burdensome to the government to provide that procedure.
-Government’s interest, including the function involved and the fiscal and administrative burdens and the additional or substitute procedural requirements.

-Does the government need to provide a post-termination hearing for disability benefits?

-Government only needs to provide post-termination hearing when social security benefits are terminated.


-Court says deprivation in this case would likely be less substantial than in Goldberg, and thus it is sufficient to follow the principle “that something less than an evidentiary hearing is sufficient prior to adverse administrative action.” Held that “All that is necessary is that the procedures be tailored, in light of the decision to be made, to ‘the capacities and circumstances of those who are to be heard,’ to insure that they are given a meaningful opportunity to present their case.

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