Critique?
Mathews v. Eldridge
- Due process case where the respondent, Eldridge, was awarded SS benefits for his disability. In May 1972, he found out that he might lose these benefits if his disability had ceased, and Eldridge disputed one characterization of his medical condition… but to no avail. The SS Administration cut off his benefits and Eldridge brought this to court saying that they took away SS benefits without process.
- There’s no debate that SS benefits in this case are statutorily created property.
- The secretary contends that the administrative procedures they used provided all the process necessary.
- Court lays out the three factors they look at in these cases:
o 1) The private interest that will be affected by the official action
o 2) The risk of an erroneous deprivation of such interest through the procedures used, and the probable value of additional or substitute procedural safeguards.
o 3) The government’s interest.
- The way the process works is that the recipient has the burden of showing that he’s unable to work. If there’s a conflict between the information that the agency concludes and what the worker says, then they have a physical assess the situation. If they go ahead and terminate benefits after that, then the administration will let the recipient have an evidentiary hearing before an SSA judge. If the SSA is wrong, they’ll pay whatever they owe.
- The lower courts found this process inadequate, and said that you must have the hearing before deprivation. The Supreme Court disagrees – can have the hearing afterwards, given the interests at stake.
- In this case, being taken off disability benefits is not as bad as being taken off welfare. Thus, this case is distinguishable from Goldberg v. Kelly. You’re not absolutely flat
ing broke, necessarily. The court acknowledges that it can take a while to get to the hearing (over a year, potentially), but they still don’t see that as being unacceptable.
- The court also looked to the fact that all the evidence used in the initial decision comes from medical examiners, so there’s likely not going to be problems with the data they come up with. The process is also open in the initial stage before the decision, giving the recipient a chance to debate certain parts of the information gathered.
- The court also says that it’s not in the public’s best interest. Too much financial and administrative toll on the government.
- So the SSA wins.
- The dissent argues that the court doesn’t actually know the hardships imposed won’t be great, so this is a bad decision.
North American Cold Storage Co. v. Chicago – Court upheld a state law providing for the destruction without prior hearing of food held in storage that authorities thought was rotting and dangerous to have around.
Gilbert v. Homar – Corut held that due process allows the suspension of a tenured campus policeman who was charged with drug offenses without any pre-suspension process and without pay. The court didn’t see any private interest for the police dude, so they said “screw him”
Problem on 52: She probably has a due process claim. She’s on foodstamps, so she has a property issue. The interest in her getting a hearing is very high, as losing her apartment = substantial loss. This is more analogous to Goldberg v. Kelly than Mathews v. Eldridge.
