Mathews v. Eldridge

424 U.S. 319 (1976)


Respondent was a recipient of Social Security disability benefits.  After receiving a completed questionnaire from respondent and considering reports from doctors and other information, the state agency informed respondent by letter that it had made a tentative determination that his disability had ceased.  The agency provided respondent with a statement of reasons and advised him that he could request reasonable time to submit additional information about his condition.  In a written response, respondent disputed one characterization of his medical condition and indicated the state already had enough information to establish his disability.  The agency then made its final determination that respondent was no longer disabled and notified him his benefits would terminate after that month.  He was also advised of his right to seek reconsideration of this determination within six months.

Procedural History

The federal district court held that the administrative procedures used to terminate respondent’s benefits abridged his right to procedural due process, and the Fourth Circuit Court of Appeals affirmed.


Does the Due Process Clause of the Fifth Amendment requires that prior to the termination of Social Security disability benefit payments the recipient be afforded an opportunity for an evidentiary hearing?

Rule / Holding

No.  Reversed.  In determining what process is due, the court must consider 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 the probable value, if any, of additional or substitute procedural safeguards; and (3) the government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.


A claimant whose disability benefits are terminated may seek reconsideration of the decision and is ultimately entitled to an evidentiary hearing before a final administrative decision is made.  If the claimant ultimately prevails, he is awarded full retroactive relief for lost payments.  Thus, his sole interest is in the uninterrupted receipt of benefits pending a final administrative decision.  But unlike the welfare recipient in Goldberg v. Kelly, eligibility for disability benefits is not based on financial need, and so the temporary deprivation is not likely to be as serious.

In addition, the potential value of a pre-termination hearing is substantially lower than in Goldberg.  The information critical to the agency’s decision usually is derived from the claimant’s questionnaire and medical sources, which are more likely to be able to communicate effectively through written documents than welfare recipients or lay witnesses.  Their conclusions are often supported by other documents such as X-Rays and lab tests.  Moreover, several safeguards exist: the disability recipient has access to all information relied on by the agency, the agency informs the recipient of its tentative decision and gives reasons, and the recipient then has an opportunity to submit additional evidence or arguments.

Finally, the administrative burden and other societal costs that would be entailed by providing pre-termination evidentiary hearings as of right would be substantial.  And cost aside, fairness does not always require judicial procedures like an evidentiary hearing.  Deference should be given to the agency concerning what process is due, especially when, as here, the claimant is able to effectively assert his claim and has a right to an evidentiary hearing and subsequent judicial review before the denial of his claim becomes final.

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