Goldberg v. Kelly
United States Supreme Court
The action was initially brought in the District Court for the Southern District of New York.
Plaintiff claimed that the New York State and City officials administering the Aid to Families with Dependent Children (AFDC) or the Home Relief Program terminated or were about to terminate plaintiff's financial aid without prior notice and hearing. Plaintiff claimed that this violated his due process of law.
Does the Due Process Clause require the recipient of financial aid from an administrative agency be afforded an evidentiary hearing before the termination of benefits?
Both sides agreed that procedural due process is applicable to the termination of welfare benefits. However, "the extent to which procedural due process must be afforded the recipient is influenced by the extent to which he may be 'condemned to suffer grievous loss' and depends upon whether the recipient's interest in avoiding that loss outweighs the governmental interest in summary adjudication."
The court then continues to lay out the reasons for and against giving pretrial hearings: Reasons for:
- Take away financial aid to the most needy without a fair hearing would put the poor in a terrible position
- Governmental interests in making sure the dignity and wellbeing of all persons within its borders
- Since most termination of aid are done without a challenge, summary adjudication saves "fisc and administrative time and energy by reducing the number of evidentiary hearings actually held.
- Conserve public money by stopping financial aid payments immediately
The court concludes that the positives out weigh the negatives. However, the court says that in order to make sure that things do not get out of control for the administrative agency, the pre-termination hearing does not have to take the form of a full judicial hearing. The pre-termination hearings must include
- the ability to orally present their case
- the ability to bring an attorney (although one does not have to be provided
- the ability to confront and cross-examine adverse witnesses
- the decision maker making a decision that rests solely on the legal rules and evidence that is brought up at the hearing.