Mathews v. Eldridge
In June 1968 plaintiff started receiving disability payments. In March 1972 plaintiff received a questionnaire from the state about the disability. He completed the questionnaire and referred to medical sources for proof. The state considered these reports and in May 1972 decided to cease the payments. When it decided, it sent a letter to the plaintiff telling him for the reason for the termination and allowed him to submit additional information. Plaintiff submitted some more evidence, but a final determination was made to cut the payments. He was given the right to seek reconsideration within six months.
Plaintiff first sued in federal district court and said that the benefits were similar to the ones in Goldburg. The court of appeals affirmed based on the district court's opinion.
The court ruled that due process is not a technical conception and it changes with time, place and circumstances. Generally determining due process requires weighing three different factors:
- private interest
- risk of erroneous deprivation of such interest
- governmental interest
The court goes on to then describe all of the administrative procedures that are associated with this type of disability payment. Despite these elaborate procedures, the district court found them unconstitutional because there was no hearing before the termination of payment. Since, if there is an error in deciding if payment should be cut off, retroactive pay, the concern here is similar to Goldberg in that these people who lose pay might put in really bad situations. However, since disability payments are not based on poverty, the court reasons that the harm would be not as bad.
The court states factors that make the procedure of cutting off disability payments fair
- reliability of medical reports
- questionnaires are based on reliable medical sources
- tentative assessments prior to cutting off benefits
- opportunity for plaintiff to submit additional evidence after tentative assessment.
The court says that the cost of having a full hearing could be high and the money to having this hearing is often taken from people who deserve the benefits.