MATTHEW V. ELDRIDGE

Matthew v. Eldridge

Matthew v. Eldridge

This due process standard requires "some kind of hearing" the form of hearing required is determined from a balancing of the competing interests at stake. The three part test is the (1) the interest of the claimant adjusted by, (2) the increased accuracy and (3) the increased burden or cost of the safeguard. In the language of Matthews v. Eldridge: (1) the private interest that will be affected by the official action, (2) the risk of an erroneous deprivation of such interest through the procedures used, and (3) the government's interest including the fiscal and administrative burdens that additional or substitute safeguards will entail.

The first step to take to balance the interests is to determine what kind of interest each of these individuals have. To have a property interest in a benefit, a person must have a legitimate claim of entitlement to it or a legitimate expectation of receiving such benefit.

The Matthews v. Eldridge balancing test was applied to determine the appropriate level of hearing. The liberty interest of the juvenile and the risk imposed on that interest were weighed against the government's interest in the transfer. It was determined that a formal trial-type hearing needed to be held before the transfer could be made because admission to a mental institution posed a substantial risk to the liberty interests of the juvenile.( C. Renneisen 1976) If an individual's statutory rights will be affected by an adjudication, the type of hearing will depend on the statute and APA in question. The Model State APA requires a formal hearing in every case of adjudication, whether or not a statute expressly requires it.117 The formal hearing protection of the Model State APA applies to every adjudication. (J. Irwi 2003) The Jail: Managing the Underclass in American Society. Berkeley: University of California Press. (Martinez, et al. 2000)

The Federal APA takes a different approach to detemining the level of hearing necessary. The protection of the Federal APA applies "in every case of adjudication required by statute to be determined on the record after opportunity for agency hearing."118 This means that the Federal APA's formal protections apply to hearings required to be on the record by a statute. A statute merely requiring a hearing, or one that does not speak to the matter, does not trigger the Federal APA requirement of a formal hearing. Mathews was decided by the Supreme Court in 1976, six years after its decision in Goldberg v. Kelly. In Goldberg, the situation was similar to that in Mathews except that the benefits at issue were welfare instead of disability. 397 U.S. 254 (1970). Because of the “individual's overpowering need in this unique situation not to be wrongly deprived of assistance”, the Court in Goldberg held that prior to termination of welfare benefits, the due process clause of the 5th amendment required an evidentiary hearing. Id. at 261. The Court reached this result based on a balancing test weighing the welfare recipient's interest in uninterrupted benefits, versus ...