Sunday, October 27, 2013

Mathews v. Eldridge case brief

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

In an action where respondent had sought an evidentiary hearing prior to termination of petitioner's Social Security disability benefit payments, certiorari was granted to the United States Court of Appeals for the Fourth Circuit.

  • Mr. Eldridge (plaintiff) began receiving Social Security benefits in June 1968. 
  • In March of 1972, the state agency in charge of monitoring Eldridge’s medical condition sent him a questionnaire. 
  • Based on Eldridge’s answers to the questions and reports from Eldridge’s doctor and a psychiatric consultant, the state agency informed Eldridge that he was no longer eligible for Social Security benefits. 
  • Eldridge disputed this decision in writing, but the state agency terminated his benefits. 
  • The Social Security Administration (SSA) accepted this determination and advised Eldridge that his benefits would terminate after that month. 
  • The notification informed Eldridge that he had the right to seek reconsideration by the state agency within six months. 
  • Eldridge did not request reconsideration, but filed a lawsuit challenging the constitutionality of the administrative procedures used to determine whether a Social Security recipient has a continuing disability. 
  • The district court and court of appeals held that Eldridge had to be afforded an evidentiary hearing under the Due Process Clause of the Fifth Amendment. Mathews, the Secretary of HEW, appealed.

  • 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.

The court reversed the lower court, because procedures in place were sufficient to satisfy due process, and the state of persons receiving disability benefits was typically not as serious as that of welfare recipients.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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