Any civilized society is expected to adequately take care of all or at least most of the needs of vulnerable people like the disabled and those who are subjected to extreme poverty. Consequently, to ensure that the disabled and those in extreme poverty can live a decent life, the United States of America came up with the social security disability (SSD) benefits. Individuals who are not able to work due to a medical condition that can last for at least one year are eligible to SSD benefits. Therefore, SSD is one of the best social security benefits that are aimed at enhancing the well-being of people, especially when they have critical health conditions that prevent them from participating in gainful employment or work. However, the administration of such programs is characterized with some challenges, particularly when there are some loopholes in laws or policies that guide their application. The loopholes in laws and policies guiding such noble programs are a hindrance to their success and attainment of the ultimate goals and objectives which are to better the lives of the disabled and the poor. The Mathews v. Eldridge case is an excellent example of how the implementation of SSD benefits program is challenging, primarily in the determination of the eligibility of the beneficiaries. Although some people may argue that the Supreme Court was wrong in ruling that there was no legal requirement for the pre-termination hearing for the recipients of SSD benefits, its final decision was right because it was based on facts and the circumstances surrounding the case.
In 1968, George Eldridge successfully applied for the SSD benefits program after she suffered from chronic anxiety and back pain that could not allow him to continue working and hence he was unable to earn a living. He was the beneficiary of the program for about four years until on May 1972 when the monitoring state agency informed him that his disability had ceased and he could no longer benefit from SSD program (Constitutional Law Reporter, 2018). The decision by the agency was based on the report by Eldridge’s doctor and that of an independent medical consultant that indicated that he could now work. Eldridge was advised by the agency to provide additional information to confirm that he was still disabled and could not work (Constitutional Law Reporter, 2018). Nevertheless, he refused to present additional information, arguing that the agency had provided enough information and proof to decide on his disability status. On the contrary, he sued the agency for not following due process in terminating her SSD benefits. The district court ruled that her termination was unconstitutional, which was later affirmed by the Court of Appeal. However, the Supreme Court overturned the ruling by the two lower courts, maintaining that pre-termination hearing is not a requirement when a person is being stopped from benefiting from the SSD program.
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One of the main reasons why the final decision by the Supreme Court was right was because Eldridge was given the opportunity to provide additional information about her disability status before the termination and he ignored (Constitutional Law Reporter, 2018). The best thing that he could have done to prove that he was still disabled was to provide information or evidence before the agency he could not still work, even though his doctor and independent medical consultant thought so. He missed the opportunity to challenge the decision of the agency even before his disability status was revoked (Lawson, Ferguson & Montero, 2005 ) . The agency was relying on the medical report from the experts, and there was no way it could challenge what the doctor said about his disability status. Hence, there was no way Eldridge could convince the judges that due process was not followed when he was given the opportunity to provide additional information and he was adamant.
The District Court mainly relied on the Goldberg v. Kelly case in determining the case that was filed by Eldridge. Whilst making its ruling on the Goldberg v. Kelly case in 1970, the Supreme Court decided that the plaintiff was entitled to an evidentiary hearing as contained in the Due Process Clause before he could be terminated from benefiting from government welfare programs for the people who are disabled and unable to work and earn a livelihood; and the extremely poor citizens. Nevertheless, both the District Court and the Court of Appeal erred in their ruling because Goldberg v. Kelly case was based on welfare benefits and not SSD benefits was in the case of Goldberg v. Kelly case. Unlike SSD benefits, welfare benefits are a statutory entitlement that every eligible US citizen must receive (Lawson, Ferguson & Montero, 2005 ) . Hence, the Supreme Court was right when it decided that due process must be followed in the Goldberg v. Kelly case before the determination. Also, the eligibility for welfare benefits is based on the financial status of the recipients. On the contrary, the eligibility of SSD is not determined by the financial status of the beneficiary (Beaubien, 2016). Therefore, the district and the appellate courts were wrong to use the Goldberg v. Kelly case to make a final ruling on the case that was filed by Eldridge because they were incompatible.
Also, the Supreme Court carefully considered the legal principles that are required to determine whether the due process should be granted or not. The first legal principle to be considered in the determination of due process is the interest of the person in retaining their beneficiary status or property or the level of injury that he or she may incur in case he or she is stopped from benefiting from government social security programs (Case Briefs, 2013). Still, while referring to the Goldberg v. Kelly case, the Supreme Court was right to conclude that the interest of Eldridge was not going to be adversely affected due to the termination of SSD benefits, especially when compared to other welfare recipients who are more poor and needy. Beneficiaries of welfare befits are extremely needy and poor people who largely depend on the government programs for their survivals. Conversely, Eldridge only had a temporary disability that ceased after four years based on the assessment by his doctor and independent medical consultant. Hence, the district court was not justified to use the Goldberg v. Kelly case to justify its ruling, and the Supreme Court was right to overturn its final decision because it was not based on the relevant reference. The district court could have realized that the eligibility of SSD benefits is not pegged on financial needs as in the case of welfare recipients.
Besides, in comparing the potential value of pre-termination hearing, the Supreme Court was justified to conclude that the Goldberg case had a higher potential value than that of Eldridge. In arriving in the final decision, the monitoring agency was required to rely on the information contained on the beneficiary questionnaire and reports from medical experts (Case Briefs, 2013). Eldridge filled out the questionnaire, which was assessed by the agency. At the same time, the medical experts gave their report on the status of Eldridge’s disability. Based on the questionnaire and the medical reports, the agency was convinced that Eldridge’s disability ceased. Hence, it was easier to determine Eldridge status than Goldberg’s financial condition, which required the consideration of complex factors. It was upon Eldridge to produce concrete evidence such as X-ray and to dispute the claims by the medical experts. By not providing additional evidence, Eldridge confirmed that the agency and the experts were correct. He was only interested in the pre-termination hearing and not to continue benefiting from the SSD benefits.
Another legal principle that is used to determine the due process is the cost and administrative burden, which the Supreme Court was right to conclude that it was substantial and could have caused a significant disruption or interferences in the operations of the agency (Case Briefs, 2013). To ascertain that Eldridge’s disability had ceased, the agency would have been required to do further X-ray and lab tests that are always costly. Besides, the agency has many patients to serve and conducting a further medical examination of Eldridge’s disability status could have disrupted its operations due to time wastage and delays. Nonetheless, in this case, a further medical examination was not necessary because Eldridge did not produce any evidence of information that contradicts the report by the experts and the agency (Lawson, Ferguson & Montero, 2005 ) . Hence, Eldridge was not entitled to due process or pre-determination hearing because his case did not pass the legal principle thresholds that are required for an evidentiary hearing in case of wrongful termination of SSD benefits.
However, some people argue that the three legal principles that guide the determination of due process are subjective. As a result, the principles give judges the opportunity to exercise their personal values and beliefs when determining important case like that of Eldridge. Also, some critics of the principles maintain that the subjective nature of the three-part test for pre-termination hearing can be misused by judges or agencies to serve the interest of the government, especially when the cost of SSD or welfare programs is high (Beaubien, 2016). Nevertheless, it is vital for the three legal principles that determine the due process to be flexible to give judges the opportunity to adequately assess specific cases based on the available facts and circumstances. The court needs some flexibility in the legal principles for accurate judgment and decisions that are aimed at delivering justice to both the plaintiff and defendants (Lawson, Ferguson & Montero, 2005 ) . For instance, without flexibility on the three legal principles, it could not have been easy for the Supreme Court to distinguish between Goldberg v. Kelly case and Eldridge case, which formed the major basis for its ruling.
Therefore, based on the facts and the legal requirements, the Supreme Court was justified to rule that pre-termination hearing was not required in the Mathews v. Eldridge case. It was clear that Eldridge did not have evidence to prove that his termination was unconstitutional and that he was legally entitled to the pre-termination hearing. The easiest action to take when he was informed that his benefits would be terminated was to produce enough evidence to contradict the decision by the agency. On the contrary, he rushed to the court to seek a pre-termination hearing, which was not required in her case. The district court and court of appeal also wrongly referred to the Goldberg v. Kelly case when making the final ruling. Although SSD benefits are aimed at benefiting individuals meet their basic needs, it should not be abused by the people and agencies. Only eligible people should be allowed to benefits from SSD and welfare programs to enhance their effectiveness in meeting the set goals and objectives.
References
Beaubien, B. V. (2016). A Matter of balance: Mathews v. Eldridge provides the procedural fairness Rhode Island’s judiciary desperately needs. Roger Williams UL Rev. , 21(3) , 355-369.
Case Briefs. (2013, November 12). Mathews v. Eldridge. Retrieved from http://www.casebriefsummary.com/mathews-v-eldridge/
Constitutional Law Reporter. (2018). Mathews v Eldridge clarifies due process requirements in administrative proceedings . Retrieved from https://constitutionallawreporter.com/2017/11/30/mathews-v-eldridge-1976/
Lawson, G., Ferguson, K., & Montero, G. A. (2005). Oh Lord, Please don't let me be misunderstood: Rediscovering the Mathews v. Eldridge and Penn Central Frameworks. Notre Dame Law Review , 81(1) , 1-52.
