Does the Fifth Amendment's Due Process Clause mandate an evidentiary hearing before the government can terminate an individual's Social Security disability benefits?

George Eldridge was receiving Social Security disability benefits when, in March 1972, he was sent a questionnaire by the state agency monitoring his medical condition. Based on his responses and reports from his physician and a psychiatric consultant, the agency made a tentative determination that Eldridge's disability had ceased in May 1972. Eldridge was informed of this and given an opportunity to provide additional information. After reviewing his written response, the state agency made a final determination that he was no longer disabled, which the Social Security Administration (SSA) accepted.

In July, Eldridge was notified that his benefits would terminate after that month. Rather than requesting reconsideration through the administrative process, Eldridge filed a lawsuit challenging the constitutionality of the procedures used for terminating disability benefits. This legal action bypassed the standard reconsideration and appeal process within the SSA system.

Eldridge initiated a lawsuit in the U.S. District Court for the Western District of Virginia, contesting the constitutionality of disability benefit termination procedures. The District Court ruled in Eldridge's favor, determining that due process mandated a pre-termination evidentiary hearing. The Secretary of Health, Education, and Welfare appealed this decision to the Court of Appeals for the Fourth Circuit, which affirmed the lower court's ruling. Subsequently, the Secretary further appealed the case to the Supreme Court.

(Powell, J.)

No. The Fifth Amendment's Due Process Clause does not mandate an evidentiary hearing before the government can terminate an individual's Social Security disability benefits. The existing administrative procedures fully comply with due process requirements. A three-factor test determines what process is due: the private interest affected, the risk of erroneous deprivation, and the government's interest. While the recipient's interest in uninterrupted benefits is significant, it is less compelling than in welfare cases. The current procedures, which rely heavily on written medical evidence, provide sufficient safeguards against erroneous termination. These procedures strike an appropriate balance between the individual's interest and the government's need for efficient administration. The risk of error in disability determinations is minimal due to the nature of medical assessments and the availability of post-termination hearings. Requiring pre-termination evidentiary hearings in all cases would impose substantial fiscal and administrative burdens on the government without significantly increasing the accuracy of determinations. The existing process, which includes notice, opportunity to submit additional evidence, and the right to appeal, adequately protects the interests of disability benefit recipients. The flexibility of due process allows for varying levels of procedural protections based on the specific context and interests involved. In this case, the current procedures provide a fair and reliable means of making disability determinations while maintaining administrative efficiency.

Dissent (Brennan, J.) Prior to termination of benefits, Eldridge must be afforded an evidentiary hearing of the type required for welfare beneficiaries under Goldberg v. Kelly. The Court's consideration that a discontinuance of disability benefits may cause only limited deprivation is speculative. The legislative determination to provide disability benefits presumes a need that should not be denigrated. This decision undermines the protections afforded to vulnerable individuals relying on government assistance and sets a concerning precedent for future due process cases involving benefit terminations.