Mathews v. Eldridge Test

MATHEWS V. ELDRIDGE TEST

A three-part test that determines whether an individual has received due process under the Constitution. The test balances (1) the importance of the interest at stake; (2) the risk of an erroneous deprivation of the interest because of the procedures used, and the probable value of additional procedural safeguards; and (3) the government's interest.

Decisions by the Supreme Court in the 1960s enhanced the due process rights of individuals under both the Fifth and Fourteenth Amendments. Aggrieved individuals used these precedents to litigate various issues involving the termination of employment, government benefits, professional licensure, and other interests involving administrative law matters. As a result, the Supreme Court had to sort out how much process was enough to constitute due process. The Court resolved this issue in Mathews v. Eldridge, 425 U.S. 319, 96 S.Ct. 893, 47 L.Ed.2d 18 (1976), when it announced a three-part balancing test that lower courts must apply when analyzing procedural due process cases.

In Mathews, the plaintiff accused the federal government of terminating his social security disability benefits without an evidentiary hearing prior to termination. The claim was that the administrative procedures in place by the government violated his constitutional right to due process. The Court acknowledged that the receipt of benefits was an important private interest, which satisfies the first part of the test focusing on whether or not a private interest is at stake. Later court decisions have shown that this part of the test is subjective, calling on courts to make judgment calls on the relative merit of the interest at stake.

The second part of the test assesses the risk of the possibility that a person will be mistakenly deprived of the interest because of the need for additional or different procedural safeguards. If the risk of error is minimal, then the need for additional procedures declines. If the risk is high then additional procedures would be merited. Government agencies also may reduce the risk of erroneous deprivation by ensuring that regulations are not arbitrary or discriminatory, and by defining reasonable classifications. In Mathews, the Court ruled that administrative procedures that were in place did not violate due process rights; the plaintiff was offered several methods to address the termination of benefits, but did not choose to employ them.

The final part of the test deals with the government's interest. The Mathews court, however, made it clear that in addition to interest, administrative burdens also must be factored into the analysis. If the need for enhanced due process is merited by the need to assure individuals that administrative actions are just, then administrative costs should not be considered. However, if the costs of the additional procedures outweigh the benefits, then the government should not be required to use additional resources. The courts give "substantial weight to the good-faith judgments" of officials charged with government administration. In Mathews, the Court ruled that an evidentiary hearing was not required prior to the termination of benefits and, therefore, the government's administrative procedures did not violate his due process rights.

Some commentators have criticized the three-part test as too subjective and impressionistic, allowing judges to impose their personal values on the relative worth of private and government interests. For example, in its ruling in Mathews the Court commented that "the fundamental requirement of due process is the opportunity to be heard 'at a meaningful time and in a meaningful manner.'" Such undefined terminology opens the door for an array of interpretations. Supporters, however, contend that the balancing of the three parts gives courts flexibility in assessing a particular set of facts. Nevertheless, the test continues to be applied by the Supreme Court and the lower courts.

further readings

Carnathan, Sean T. 1993. "Due Process and the Independent Medical Examiner System in the Maine Workers' Compensation Act." Maine Law Review 45.

Mashaw, Jerry L. 1976. "The Supreme Court's Due Process Calculus for Administrative Adjudication in Mathews v. Eldridge : Three Factors in Search of a Theory of Value." University of Chicago Law Review 44.

Schwartz, Bernard. 1993. A History of the Supreme Court. New York: Oxford Univ. Press.