Summary of Goldberg v. Kelly
Citation: 397 U.S. 254 (1970)
Relevant Facts: Respondents were beneficiaries of public financial assistance programs in New York City, represented in the underlying suit by named plaintiff John Kelly. As recipients of Aid to Families with Dependent Children (AFDC) funds, they claimed that that their benefits were being, or about to be, terminated without notification or a proper hearing. Kelly filed suit on behalf of the plaintiffs, demanded notice of termination and a fair hearing. After their complaint was filed, the City adopted procedures that provided notice to beneficiaries that would be subject to possible termination of benefits, but did not provide them with a pre-termination hearing, the opportunity to appear, or the chance to review the evidence that lead to the decision in their cases. Beneficiaries would, however, be entitled to a post-termination review, known as a “fair hearing", and challenge the determination. Kelly and the other appellees then challenged the constitutional sufficiency of these new procedures, claiming that beneficiaries of statutory entitlements are entitled to due process regarding any cancellation of benefits. The District Court agreed, ruling that a pre-termination review was required as a minimum guarantee of basic due process. Goldberg, as Commissioner of Social Services for the City of New York, was one of several named plaintiffs in the case. Goldberg appealed the district court’s determination.
Issue: What, if any, review are beneficiaries of statutory entitlements constitutionally entitled to prior to termination of their benefits under procedural due process requirements?
Holding: Yes, beneficiaries are entitled to a per-cancellation evidentiary hearing before an impartial decision-maker, consistent with due process. The State’s interest in preventing fiscal and administrative burdens does not outweigh either State interest in preventing erroneous termination of benefits or the beneficiary’s interest in uninterrupted benefits to which they are entitled.
Reasoning: Justice Brennan delivered the majority opinion. At the outset, Justice Brennan noted that not all terminations of government benefits require notice or justification, but pointed out that those that depend on benefits for subsistence (such as the appellees here) are particularly vulnerable to the loss of benefits. The majority noted that the importance of uninterrupted benefits for proper beneficiaries serve the interests of the State as well, having established the assistance programs and having an obvious interest in seeing aid reach intended targets. The interests of the State and of beneficiaries outweigh the asserted interest in conserving fiscal and administrative resources. The Court concluded that beneficiaries are entitled to procedural due process regarding determination of benefits, including a pre-termination evidentiary hearing. While the Court agreed with the district court that the hearing need not be judicial, an administrative hearing should include the following: timely and adequate notice, an opportunity to defend, the ability to confront witness, the chance to present evidence, an impartial decision-maker (not involved in the determination leading to the review), and provision of the basis for the ultimate determination. While the Court concluded that hearings need not produce written opinions, and that beneficiaries were not entitled to council, there should still be an adequate basis for the determination provided to the beneficiary, who should be afforded the opportunity to independently secure counsel. Welfare benefits, as a matter of statutory entitlement, should reach all appropriate beneficiaries while allowing reasonable opportunity to prevent misuse and review appropriate cases. However, beneficiaries are entitled to basic procedural due process protections, notwithstanding the obvious government interest in conserving limited resources as a part of the necessary review process.
Dissent: Justice Black dissented, discussing both the bloated welfare rolls in New York City and the opportunity to abuse public benefits systems. While he shared the majority’s view that it may well be unconscionable to terminate benefits for deserving recipients, he found no justification for the majority’s holding in the text of the Constitution. Rather, he concluded that the Court had merely read due process to require the preferred result. Accordingly, Justice Black would have preferred to leave administration of the welfare system, admittedly a relatively new experiment at the time, to the legislature for administration.
Conclusion: Public assistance beneficiaries are entitled to pre-termination evidentiary review of their cases, and the opportunity to challenge the attempt to terminate benefits.