Mathews V. Etheridge

424 U.S. 319 (1976)

 

Background

George Eldridge, who had originally been deemed disabled due to chronic anxiety and back strain, was informed by letter that his disability status was ending and that his benefits would be terminated. Social Security Administration procedures provided for ample notification and an evidentiary hearing before a final determination was made, but Eldridge’s benefits were cut off until that hearing could take place. Eldridge challenged the termination of his benefits without such a hearing.

Relevancy for School Disciplinary Hearings

Defining balancing test for how much process is due.

Held

The Court identified three factors to be considered in determining what process is due when an individual is faced with the deprivation of a property interest.

First, the private interest that will be affected by the official action; Second, 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 Third, the Government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirements would entail.

Here, where the particular issue was whether the lack of an evidentiary hearing prior to the termination of disability benefits violated the Due Process Clause of the Fifth Amendment, the Court held that the initial termination of Eldridge’s benefits without a hearing did not violate due process. The Court noted that due process was “flexible” and called for “such procedural protections as the particular situation demands.” 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”