Mathews v. Eldridge, 424 U.S. 319 (1976)

Author: Powell (majority) Outcome: Government wins ($d = 0$: no pretermination hearing required) Concurrences: None Dissents: Brennan, joined by Marshall

1. Holding ($H_t$)

"We conclude that an evidentiary hearing is not required prior to the termination of disability benefits and that the present administrative procedures fully comport with due process." (p. 349)

As constraint on admissible $(w, c)$: The holding rules out any decision rule requiring a pretermination evidentiary hearing for Social Security disability benefits under the Due Process Clause. The decision permits termination of benefits based on written submissions and medical evaluations without an oral hearing, provided post-termination processes are available.

What the holding does NOT constrain:

Whether other types of benefits or entitlements require pretermination hearings
The specific procedural safeguards required in other contexts
The adequacy of post-termination procedures in different factual scenarios
The applicability of this decision to non-disability-related benefits or entitlements

2. Fact vector $z_t$

2a. Raw salient facts

Nature of disability benefits: Benefits are not based on financial need but on medical disability (p. 332). Favors: government.
Medical assessment: Decision to terminate benefits relies on "routine, standard, and unbiased medical reports by physician specialists" (p. 343). Favors: government.
Written submissions: Recipients have the opportunity to submit written evidence and arguments before termination (p. 345). Favors: government.
Retroactive relief: Recipients are entitled to full retroactive payments if they prevail after termination (p. 349). Favors: government.
Potential deprivation: Termination may impose hardship, but recipients have access to other forms of assistance (p. 343). Favors: government.
Administrative burden: Requiring pretermination hearings would impose significant fiscal and administrative burdens (p. 347). Favors: government.
Private interest: The private interest affected is the uninterrupted receipt of benefits pending final decision (p. 341). Favors: plaintiff.

2b. Dimension mapping

Dimension	Value	Raw fact(s) mapped	Textual basis
D1 Liberty interest type	Economic	Nature of disability benefits	Benefits are not based on financial need but on medical disability (p. 332)
D2 Historical grounding	Low	—	No historical requirement for pretermination hearings in disability benefits context
D3 Level of generality	Narrow	Nature of disability benefits	Focus on specific procedures for disability benefits (p. 332)
D4 Government interest strength	Strong	Administrative burden	Significant fiscal and administrative burdens (p. 347)
D5 Intrusion severity	Low	Retroactive relief	Full retroactive payments if recipient prevails (p. 349)
D6 Methodology	Balancing	Three-factor test	Private interest, risk of erroneous deprivation, government interest (p. 335)
D7 Institutional setting	Welfare/administrative	Nature of disability benefits	Administered by SSA and state agencies (p. 335)
D8 Precedent density	High	Reliance on Goldberg v. Kelly	Distinguishes from welfare context (p. 343)

Unmapped facts:

Potential deprivation does not map cleanly to any existing dimension. It is a factual predicate about the impact of termination, relevant to assessing the severity of intrusion (D5), but not directly addressed by the existing dimensions.

Notable: The Court emphasizes the distinction between disability and welfare benefits, focusing on the medical basis for disability benefits and the availability of retroactive relief, which reduces the severity of deprivation.

3. Treatment of prior holdings ($\mathcal{F}_t$ update)

Goldberg v. Kelly (1970)

Status: Distinguished. The Court notes that Goldberg involved welfare benefits based on financial need, whereas disability benefits are not need-based (p. 343).
Characterization: Goldberg required pretermination hearings for welfare benefits due to the immediate deprivation of subsistence-level income.
Model interpretation: The decision narrows the applicability of Goldberg's requirement for pretermination hearings, limiting it to contexts where the deprivation is immediate and based on financial need.

Richardson v. Perales (1971)

Status: Relied on. The Court cites Perales for the reliability of written medical reports in disability determinations (p. 343).
Characterization: Perales upheld the use of written medical reports as substantial evidence in disability determinations.
Model interpretation: Reinforces the sufficiency of written submissions in disability contexts, supporting the decision to forgo pretermination hearings.

Arnett v. Kennedy (1974)

Status: Relied on. The Court references Arnett's acceptance of less formal procedures for federal employee dismissals (p. 345).
Characterization: Arnett upheld procedures that included notice and opportunity to respond in writing before dismissal.
Model interpretation: Supports the adequacy of written procedures prior to termination, aligning with the balancing approach.

4. Overruling (constraint removal at cost $C$)

No overruling in this case. The Court distinguishes rather than overrules Goldberg v. Kelly, emphasizing the different nature of disability benefits compared to welfare benefits. The decision clarifies the scope of Goldberg without removing its core constraint on welfare benefits.

5. Breadth

Narrow reading (what the Court explicitly holds):

No pretermination evidentiary hearing is required for Social Security disability benefits.
Applies specifically to disability benefits, not extending to other types of entitlements.

Broad reading (what the reasoning supports):

The decision could support similar procedural frameworks for other non-need-based benefits where retroactive relief is available.
Suggests a general principle that written submissions and post-termination processes can suffice where immediate deprivation of subsistence is not at issue.

Breadth ambiguity: The decision leaves open whether other types of benefits with different characteristics might require pretermination hearings. The emphasis on the medical basis for disability benefits and the availability of retroactive relief suggests a narrower application, but the balancing test could be applied in other contexts.

6. Concurrences / dissents (alternative admissible theories)

Brennan, joined by Marshall (dissenting)

Alternative constraint structure: Brennan would impose a requirement for pretermination evidentiary hearings for disability benefits, aligning with the Goldberg standard for welfare benefits.
Key disagreement: Brennan emphasizes the potential deprivation and hardship caused by termination, arguing that the need for benefits presumes a significant private interest.
Model interpretation: Brennan's dissent suggests a broader application of due process protections, prioritizing the private interest and potential harm over administrative burdens.

7. Reasoning revealing implicit weights on dimensions

Balancing test (D6 weight is high):

"[D]ue process is flexible and calls for such procedural protections as the particular situation demands." (p. 335)

The Court emphasizes the balancing approach, weighing private interests, risk of erroneous deprivation, and government interests.

Government interest (D4 weight is strong):

"Requiring an evidentiary hearing upon demand in all cases prior to the termination of disability benefits would entail fiscal and administrative burdens out of proportion to any countervailing benefits." (p. 347)

The decision highlights the strong government interest in conserving resources, influencing the procedural adequacy assessment.

Private interest and deprivation (D5 weight is low):

"Since a recipient whose benefits are terminated is awarded full retroactive relief if he ultimately prevails, his sole interest is in the uninterrupted receipt of this source of income pending final administrative decision on his claim." (p. 341)

The Court downplays the severity of deprivation due to the availability of retroactive relief, reducing the weight on the private interest dimension.