Mathews v. Eldridge

424 U.S. 319 (1976)

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Nature of the Case

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Facts

Eldridge (P) was given Social Security disability payment. These payments were stopped four years later. In March 1972, he received a questionnaire, and he completed the questionnaire, indicating that his condition had not improved and identifying the medical sources, including physicians, from whom he had received treatment recently. The state agency then obtained reports from his physician and a psychiatric consultant. The agency informed Eldridge by letter that it had made a tentative determination that his disability had ceased in May 1972. The letter included a statement of reasons for the proposed termination of benefits and advised Eldridge. He was given a chance to dispute, and he did so by letter but his benefits were terminated, and he was also informed of his ability to dispute within 6 months. P sued pending a hearing on the issue of his disability. The Secretary moved to dismiss on the grounds that the benefits had been terminated in accordance with valid administrative regulations and procedures and that he had failed to exhaust available remedies. The District Court reasoned that disability determinations may involve subjective judgments based on conflicting medical and nonmedical evidence. The District Court held that, prior to termination of benefits, Eldridge had to be afforded an evidentiary hearing of the type required for welfare beneficiaries under Title IV of the Social Security Act. The Court of Appeals for the Fourth Circuit affirmed the injunction barring termination of Eldridge's benefits prior to an evidentiary hearing. Matthews (D) appealed.