Matthews v. Eldridge
424 U.S. 319 (1976)
- Eldridge was getting disability benefits, and they were terminated without a hearing. He sued, claiming that the 5th Amendment required due process.
- Although Eldridge did receive notice and the opportunity to comment in writing, he argued that Goldberg v. Kelly (397 U.S. 254 (1970)) required a full evidentiary hearing prior to having the benefits cut off.
- The US Supreme Court found that an evidentiary hearing was not required under the due process clause of the 5th Amendment.
- The US Supreme Court agreed that the termination of benefits did trigger some kind of due process.
- However, the Court found that when determining the amount of due process required there should be a balancing act between the interests affected and the administrative burden.
- The Court suggested that in order to determine what due process is appropriate, the courts should assess:
- The private interest affected by the agency’s action.
- The risk of error inherent in the agency’s existing procedures.
- The government’s interest in maintaining the existing procedures without undue fiscal and administrative burden.
- These three are now known as the Matthews Factors.
- In this case, the Court found that the current administrative procedures were sufficient to guarantee Eldridge’s due process, since a pre-termination hearing would be a large administrative burden on the State, and not having a hearing would only be a minor inconvenience to Eldridge.
- This contrasts to Goldberg in which the Court found that a pre-termination hearing was warranted because the case involved welfare benefits and people could starve without them. Therefore the private interest was greater.
- See also Arnett v. Kennedy (416 U.S. 134 (1974)), which said that post-termination hearings were sufficient for situations where there was not the ‘brutal need’ in Goldberg.
- In Arnett, a Federal employee was fired and without what he felt was due process. The court in that case found that since they could always reinstate his job and give him back pay later, the agency didn’t need to hold the hearing prior to firing the employee.
- One criticism with this decision is that the court gives no guidance on how to compare the factors. For example, how do you compare the risk of error to the fiscal burden to the agency? It’s apples and oranges. It is impossible to create a common metric.
- For example, if there is a 15% chance of error, and the fiscal burden was $1M, is a pre-termination hearing required or not?
- Since this decision, most of the subsequent cases require notice, an opportunity to be heard, and a requirement for a statement of reasons for decisions. Most cases do not require a pre-termination hearing or an oral hearing.