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.
