Matthews v Eldridge Cases

The 5th and 14th Amendment – Due Process

The concept of due process is one of the important principles in the United States Constitution and judicial process. It is an old notion that started vaguely in the Magna Carta of England (Kohn, 2013). In the U.S. Constitution, the due process clause is in the 5th and 14th amendments. The due process clause in the U.S. Constitution requires fundamental procedural fairness and the respect of an individual’s legal rights by the state. Under the 5th and 14th amendments, due process is classified into two i.e. procedural due process and substantive due process. The due process doctrine has been the subject of numerous judicial considerations including in the Matthews v. Eldridge case. This paper examines this case in terms of whether it provides sufficient guidelines for a court to ascertain whether procedural due process has been properly provided.

The Matthews v. Eldridge Case

As noted by Kohn (2013), Matthews v. Eldridge is one of the 20th Century cases relating to the doctrine of due process. George Eldridge was a beneficiary of Social Security disability benefits from June 1968 due to chronic anxiety and back strain. Eldridge was later found to have diabetes and was informed by a letter from the state agency that his disability status was ending and his benefits would be terminated in May 1972. Eldridge responded by stating that he had arthritis of the spine and not a strained back. He also stated his belief that the state agency had sufficient information to establish his disability. However, the state agency upheld its decision, which was also accepted by the Social Security Administration (SSA). SSA notified him that his benefits would end after a month and his right of reconsideration by the agency within 6 months. Eldridge challenges the constitutionality of the termination of his benefits at the district court on grounds that due process was not followed based on the Fifth Amendment. SSA procedures provided for sufficient notification and evidentiary hearing prior to a final determination. In his case, Eldridge argued that the benefits were terminated before such a hearing could take place. The district court ruled in favor of Eldridge and argued that the termination breached procedural due process. The ruling was upheld by the court of appeals, which agreed with the district court. The Supreme Court ruled that Eldridge’s initial termination did not violate due process as an evidentiary hearing is not required prior to termination of disability benefits (Law Library, n.d.). In a majority opinion, Justice Powell stated that the district court and the court of appeals did consider the elaborate administrative procedures provided in addition to the evidentiary hearing.

Matthews Test of Procedural Due Process

Matthews v. Eldridge case has been quoted in cases on the definition of due process. In cases of this nature, the three factors for the resolution of issues on constitutional sufficiency of administrative process have been relied upon. This case is one of the landmark rulings on the issue of procedural due process. Posthuma (2003) defines procedural due process as a legal concept on the fairness of legal proceedings in a judicial setting. Based on the 5th Amendment to the U.S. Constitution, procedural due process requires the state to take away things from individuals only if due process is used. In Matthews v. Eldridge, the Supreme Court sought to determine whether taking away Eldridge’s Social Security disability benefits violated due process. The determination of this case established a three-part test to determine whether one has obtained due process based on constitutional provisions. Matthew’s test include three parts i.e. the significance of the interest at stake, the risk of a wrongful withdrawal of the interest due to process used and possible value of extra procedural protections, and the government’s interest (Mikula, Mabunda & Marion, 1999). The three-part balancing test must be applied by courts when examining cases regarding procedural due process.

On the Matter of Whether Matthews Provides Sufficient Guidelines

As previously mentioned, Matthews v. Eldridge case has been quoted in other cases on procedural due process. Justice Powell noted that the district court and the court of appeals failed to consider the elaborate administrative procedures established by SSA to determine termination of benefits. The lower courts seemingly relied on only one administrative procedure i.e. evidentiary hearing before termination to determine whether due process was violated. By relying on only one part of the elaborate administrative procedure, the lower courts seemingly erred in their judgments. As shown in the Supreme Court’s evaluation of the other administrative procedures proved that procedural due process was followed in terminating Eldridge’s Social Security disability benefits.

The three-part balancing test announced by the Supreme Court that must be applied by lower courts in analysis cases on procedural due process provides sufficient guidelines. Matthews’ test provides sufficient guidelines for courts to determine procedural due process issues by promoting holistic and objective analysis. In this case, the courts consider the various administrative processes before ruling on whether due process was violated. These guidelines ensure that courts adopt a holistic view and approach rather than rely on only one or some parts of the administrative procedures.