Mathews v. Eldridge

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1976 United States Supreme Court case

Mathews v. Eldridge, 424 U.S. 319 (1976), is a landmark decision of the Supreme Court of the United States that held that individuals have a statutorily granted property right in Social Security benefits, and the termination of such benefits implicates due process but does not require a pre-termination hearing. The case is significant in the development of American administrative law .

Legal principles

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Determining the constitutional sufficiency of administrative procedures, prior to the initial termination of benefits and pending review, requires consideration of three factors:

The interests of the individual in retaining their property and the injury threatened by the official action;
The risk of error through the procedures used and probable value, if any, of additional or substitute procedural safeguards;
The costs and administrative burden of the additional process, and the interests of the government in efficient adjudication.[1]

The Court determined that Social Security benefits are a statutorily-created property right and so implicate due process .[2]

However, after balancing the three factors, the Court ruled that the administrative procedures in place were constitutional and held that termination of Social Security benefits does not require a pre-termination hearing. See Mathews v. Eldridge, 424 U.S. 319, 347–349 (1976).

Background

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The Social Security Administration terminated Eldridge's benefits by its normal procedures. However, Eldridge was not provided with a hearing before the termination of his benefits in which he could argue for a continuation of the benefits. He sued even though he had not exhausted his post-termination administrative remedies. The district court held that the termination was unconstitutional, and the court of appeals affirmed.