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Mathews v. Eldridge
 | |
| Mathews v. Eldridge | |
| Reference: 424 US 319 (1976) | |
| Term: 1975-1976 | |
| Important Dates | |
| Argued: October 6, 1975 Decided: February 24, 1976 | |
| Outcome | |
| United States Court of Appeals for the 4th Circuit reversed | |
| Majority | |
| Chief Justice Warren Burger • Byron White • Potter Stewart • Harry Blackmun • Lewis Powell • William Rehnquist | |
| Dissenting | |
| Thurgood Marshall • William Brennan | |
Mathews v. Eldridge is a case decided on February 24, 1976, by the United States Supreme Court in which the court held that the termination of disability benefits prior to an evidentiary hearing does not violate an individual's due process rights under the Constitution. In the case opinion, the court developed a three-part balancing test, known as the Mathews v. Eldridge test, for lower courts to apply when determining whether or not an individual has received due process during administrative proceedings.[1][2]
Why it matters: The court developed a three-part balancing test, known as the Mathews v. Eldridge test, for lower courts to apply when determining whether or not an individual has received due process during administrative proceedings. Courts must consider (1) the private interest at stake, (2) the effect on the private interest in the event of an erroneous determination as well as the value of any additional procedural safeguards, and (3) the government's interest, including the potential administrative burden of additional procedural safeguards.[2][3]
Background
| Administrative State |
|---|
|
| Five Pillars of the Administrative State |
| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
| Click here for more coverage of the administrative state on Ballotpedia |
- See also: Due process
George Eldridge was granted disability status due to back strain and chronic anxiety in June 1968. He received a letter in May 1972 from the state agency monitoring his benefits informing him of the agency's determination that his disability had ceased. The Social Security Administration (SSA) accepted the state agency's determination and notified Eldridge in July that his benefits would end the following month. Eldridge challenged the agency's action, arguing that the termination of his disability benefits prior to the opportunity for an evidentiary hearing violated his due process rights.[3]
Eldridge based his argument on the U.S. Supreme Court's decision in Goldberg v. Kelly, which established the right to a hearing prior to the termination of welfare benefits. Then-U.S. Secretary of Health, Education, and Welfare Forrest Mathews, who delegated the administration of disability benefits to the SSA in accordance with the Vocational Rehabilitation Act of 1920, disagreed with Eldridge's position. Mathews argued that the SSA had followed the required administrative regulations. He also stated that the Goldberg decision was not controlling because the process for determining disability benefits relies on medical evidence while the process to determine welfare benefits relies on financial need.[1][3]
The district court ruled in favor of Eldridge, arguing that the interest of disability recipients in receiving uninterrupted benefits was indistinguishable from that of welfare recipients. The court claimed that the agency had violated Eldridge's due process rights by failing to hold an evidentiary hearing prior to terminating his disability benefits. The United States Court of Appeals for the 4th Circuit affirmed the lower court's ruling.[3]
Oral argument
Oral arguments were held on October 6, 1975. The case was decided on February 24, 1976.[1]
Decision
The United States Supreme Court reversed the lower court's ruling in a 6-2 decision. Justice John Paul Stevens did not take part in the decision. The majority opinion was written by Justice Lewis Powell and joined by Chief Justice Warren Burger and justices Byron White, Harry Blackmun, Potter Stewart, and William Rehnquist. Justice William Brennan issued a dissenting opinion, which was joined by Justice Thurgood Marshall.[3]
Opinions
Opinion of the court
The court held that the termination of Eldridge's disability benefits prior to an evidentiary hearing did not violate his due process rights. The court reached its conclusion by developing a three-part test to determine whether or not an individual has received due process during administrative proceedings:
| “ | Resolution of the issue here involving the constitutional sufficiency of administrative procedures prior to the initial termination of benefits and pending review, requires consideration of three factors: (1) the private interest that will be affected by the official action; (2) the risk of an erroneous deprivation of such interest through the procedures used, and probable value, if any, of additional procedural safeguards; and (3) the Government's interest, including the fiscal and administrative burdens that the additional or substitute procedures would entail.[4] | ” |
Since hearings concerning disability benefits rely heavily on standardized medical documentation, the court found that such hearings are of less value than those concerning welfare benefits. Moreover, the court determined that the appeal process provided Eldridge with full access to the information in his case and afforded him ample opportunities to submit additional evidence. Writing for the majority, Justice Lewis Powell further argued that creating a requirement for an evidentiary hearing before the termination of each disability benefits case would create an administrative burden:[3]
| “ | Requiring an evidentiary hearing upon demand in all cases prior to the termination of disability benefits would entail fiscal and administrative burdens out of proportion to any countervailing benefits. The judicial model of an evidentiary hearing is neither a required, nor even the most effective, method of decisionmaking in all circumstances, and here, where the prescribed procedures not only provide the claimant with an effective process for asserting his claim prior to any administrative action, but also assure a right to an evidentiary hearing, as well as subsequent judicial review before the denial of his claim becomes final, there is no deprivation of procedural due process.[3][4] | ” |
The court also observed that the termination of disability benefits does not impact individuals and families in the same manner as welfare benefits. If the disabled worker's need were to escalate, the jusitices argued, welfare benefits would then become available:[3]
| “ | In view of the torpidity of this administrative review process and the typically modest resources of the family unit of the physically disabled worker, the hardship imposed upon the erroneously terminated disability recipient may be significant. Still, the disabled worker's need is likely to be less than that of a welfare recipient. In addition to the possibility of access to private resources, other forms of government assistance will become available where the termination of disability benefits places a worker or his family below the subsistence level.[3][4] | ” |
Dissenting opinion
In his dissent, Justice William Brennan countered the court's claim that the termination of disability benefits would not impact an individual in the same manner as the termination of welfare benefits. He argued that such a claim was speculative and illustrated his position by highlighting Eldridge's circumstances—in which the termination of his disability benefits resulted in the foreclosure of his home, among other financial hardships. Brennan concluded, "Finally, it is also no argument that a worker, who has been placed in the untenable position of having been denied disability benefits may still seek other forms of public assistance."[3]
Noteworthy events
California man detained 17 years released under Mathews v. Eldridge precedent (2018)
A three-judge panel of the California Second District Court of Appeal ordered the release on September 12 of George Vasquez, a California man who had been detained for 17 years awaiting trial for commitment as a sexually violent predator, on the grounds that the state had violated Vasquez’s due process rights under the 14th Amendment. The panel consisted of judges Gail Ruderman Feuer, Dennis Perluss, and Laurie Zelon.[5]
Vasquez was convicted in 1995 of committing lewd acts on a child and served 12 years in state prison. Prior to his scheduled release in 2000, Los Angeles County prosecutors petitioned to have Vasquez committed to a state hospital as a sexually violent predator for two years. Instead, Vazquez’s hearing and trial dates were delayed for the next 17 years in order to allow for a series of six court-appointed attorneys to prepare for trial. Vasquez objected to the delays in his case in 2016.[5]
Superior Court Judge James N. Bianco dismissed the prosecutors’ petition in January 2018. Bianco argued that the breakdown in the state’s public defender system had violated Vasquez’s right to timely proceedings. The appellate panel later upheld Bianco’s decision, which was based in part on U.S. Supreme Court precedent concerning due process in Mathews v. Eldridge.[5]
The California appellate panel applied the three-part Mathews v. Eldridge test in the context of Vasquez’s pre-trial delay pending an involuntary civil commitment. According to the test, the panel found that (1) detainment awaiting trial put Vasquez’s liberty at stake, (2) the length of Vasquez's detainment deprived him of his liberty, and (3) the government would not have suffered an additional administrative burden by going to trial in two years as opposed to delaying the trial for 17 years.[5][6]
See also
- Due process
- Goldberg v. Kelly
- Supreme Court of the United States
- Ballotpedia's administrative state coverage
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Mathews v. Eldridge," accessed September 13, 2018
- ↑ 2.0 2.1 West's Encyclopedia of American Law, "Mathews v. Eldridge Test," accessed September 14, 2018
- ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 JUSTIA, "Mathews v. Eldridge," accessed September 13, 2018
- ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 5.0 5.1 5.2 5.3 Courthouse News Service, "Man Held 17 Years Without Trial Ordered Free by Appellate Court," September 12, 2018
- ↑ SECOND APPELLATE DISTRICT DIVISION SEVEN, "THE SUPERIOR COURT OF LOS ANGELES COUNTY v. GEORGE VASQUEZ," September 12, 2018
