Summary of Mathews v. Eldridge (1976)
Relevant Facts: Eldridge’s disability benefits were terminated without any hearing or any other due notice.
Issue: Under constitutional law, did the termination of the benefits without any evidentriary hearing violate the Due Process Clause of the 5th Amendment?
Court’s Rationale/Reasoning: Unlike Goldberg, Eldridge’s benefits were not based on need, but rather on other factors designated by statute. The degree of potential deprivation is significantly less than that of Goldberg as well. As to the length of wrongful deprivation exceeds one year, and is also significantly less in scope than in Goldberg. Despite the fact that a person on disability is likely to be at some hardship, the Court reasoned that it is not more than that of a welfare recipient.
As to the fairness aspect, the Court found that there were numerous safeguards to prevents errors in making decisions to terminate disability benefits and argued that “[a]t some point the benefit or an additional safeguard to the individual affected by the administrative action and to society, in terms of increased assurance that the action is just, may be outweighed by the cost.”
As to the public interest, the burden actually weighs more on Eldridge, as the Court cites the many hearings it would take to get benefits back, as well as the increased costs of providing benefits to that person while they wait to have their day in court or in a proceeding, but not that expensive. However, the Court did find that if the government were forced to pay out to everyone whose claims were waiting, it could also be serving the interests of those who have completely ridiculous claims, thus the cost on taxpayers and the agencies would be burdened significantly from such a policy.
Rule: The nature of the hearing must be commensurate with the interest affected, taking into account the state’s administrative needs:
All courts must now employ the Mathews balancing test to determine the type of procedures that are required by due process when a governmental action would deprive an individual of a constitutionally protected liberty or property interest. On the individual’s side, a court must assess two factors:
1) The importance of the individual liberty or property interest at stake (private interest);
2) The extent to which the requested procedure may reduce the possibility of erroneous decision-making (government’s interest).
On the other side of the balancing scale, the court must assess the governmental interest in avoiding the increases administrative and fiscal burdens which result from increased procedural requirements.
(risk that procedures used will lead to erroneous decisions)
Important Dicta: No.