MATHEWS v ELDRIDGE  Court said that Salfi case consists of 2 elements
424 US 319 / FEB 24, 1976 / Justice Powell / Cardinal Primary Rights / LTLimbaring 1. Claim for benefits shall have been presented to the Secretary (NON WAIVABLE)
NATURE Ceritiorari to the US CA
PETITIONERS Matthews
RESPONDENTS Eldridge
SUMMARY.  Eldridge, who had originally been deemed disabled due to chronic anxiety and
back strain, was informed by letter that his disability status was ending and that his benefits
would be terminated. Social Security Administration procedures provided for ample
notification and an evidentiary hearing before a final determination was made, but Eldridge's
benefits were cut off until that hearing could take place. Eldridge challenged the termination
of his benefits without such a hearing.
DOCTRINE.
Due process is flexible and calls for such procedural protections as the particular situation
demands
FACTS.
 In 1968, Eldridge was awarded cash benefits under the disability insurance benefits program
created by the 1956 Amendments to the Social Security Act. These cash benefits are
provided to workers during periods in which they are completely disabled
 In 1972, a questionnaire from the state agency charged with monitoring Eldrige’s condition
was sent to the latter. He indicated thereon that his condition had not improved
 The agency then obtained reports from his physician and psychiatric consultants. After
which, they made a tentative determination that Eldridge’s disability has ceased. Their letter
included a statement of reasons and that Eldridge may request a reasonable time in which to
obtain and submit additional information pertaining to his condition
 Eldridge disputed the agency’s findings but still the latter made a final determination that
Eldridge ceased to be disable in 1972.
o The final determination was accepted by the Social Security Administration which
notified Eldridge that his benefits would terminate after that month and that he may seek
reconsideration of the state agency’s initial determination within 6 months.
 Instead of requesting a reconsideration, Eldridge filed this action to challenge the
constitutional validity of the procedures established by the Secretary of Health for assessing
whether there exists a continuing disability and sought reinstatement of benefits pending
hearing.
o He relied exclusively upon the case of Goldberg v Kelly which established the right to
an evidentiary hearing prior to termination of welfare benefits.
 Secretary of Health contends that Goldberg case isn’t controlling since the eligibility for
disability benefits unlike eligibility for welfare benefits is NOT BASED ON FINANCIAL
NEEDS; that disability benefits turn primarily on medical evidence.
ISSUES & RATIO.
1. WON the District Court has jurisdiction over the Suit – YES.
 ACC TO SECRETARY: District Court has no jurisdiction as there has been no exhaustion
of administrative remedies. He should’ve sought the reconsideration by the State Agency of
its initial determination. As has been held in Weinberger v Salfi: there can be no judicial
review of a denial of claim of disability benefits unless there has been a: (1) final decision
of the Secretary after (2) hearing. (i.e. 2 requirements of final decision and hearing)
2. Exhaustion of Administrative Remedies (WAIVABLE)
 Because Eldridge’s answers to the questionnaire and his letter to the state agency
specifically presented the claim that his benefits should not be terminated because he was
still disabled; the first element has been satisfied.
 Since the second element can be waived, Court has jurisdiction over the case.
2. WON evidentiary hearing is required prior to the termination of Social Security
disability payments and the administrative procedures prescribed in the act does not
afford due process. – NO. Evidentiary hearing is NOT required.
 Due process requires an evidentiary hearing prior to the deprivation of property interest
even if such hearing is provided thereafter. Due process is not a technical conception with
fixed content unrelated to time place and circumstances. It is flexible and calls for such
procedural protections as the particular situation demands
 Accordingly, the resolution of the issue here requires consideration of three factors:
1. Private interests that will be affected by the official action
2. Risk of an erroneous deprivation of such interest through the procedures used and
the probable value, if any, if additional or substitute procedural safeguards; and
3. The government’s interest including the function involved and the fiscal and
administrative burdens that the additional or substitute procedural requirements
would entail.
 In order to establish initial and continued entitlement to disability benefits, a worker must
demonstrate that he is unable to engage in any substantial gainful activity due to physical or
mental impairment.
o To satisfy this test the worker bears a continuing burden of showing by means of
medically acceptable clinical and laboratory diagnostic techniques that he has an
impairment of such severity.
 (COURT COMPARED DISABILITY BENEFITS FROM WELFARE BENEFITS TO
JUSTIFY THAT EVIDENTIARY HEARING IS NOT REQUIRED.)In this case the private
interest that will be adversely affected by an erroneous termination of benefits is likely to be
less in the case of a disabled worker than in the case of a welfare recipient, like the
claimants in Goldberg v Kelly 
o Eligibility for disability payments is not based on financial need unlike welfare
benefits, and, although hardship may be imposed upon the erroneously terminated
disability recipient, his need is likely less than the welfare recipient.
o The medical assessment of the worker's condition also implicates a more sharply
focused and easily documented decision than the typical determination of welfare
entitlement. The decision whether to discontinue disability benefits will normally turn
upon "routine, standard, and unbiased medical reports by physician specialists" whilein
welfare benefits, a wide array of information and the credibility of witnesses are often
very critical in decision making processes. In a disability situation, the potential value
of an evidentiary hearing is thus substantially less than in the welfare context.
o In welfare benefits, written submissions do not provide an effective means for the
recipient to communicate his case to the decision-maker as they lack the educational
attainment necessary to write effectiverly. While in disability benefits, written
submissions provide the disability recipient with an effective means of
communicating his case to the decisionmaker. The detailed questionnaire identifies
 with particularity the information relevant to the entitlement decision. Information
critical to the decision is derived directly from medical sources. Finally, prior to
termination of benefits, the disability recipient or his representative is afforded full
access to the information relied on by the state agency, is provided the reasons
underlying its tentative assessment, and is given an opportunity to submit additional
arguments and evidence

 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. The judicial model of an evidentiary hearing is neither a
required, nor even the most effective, method of decision making in all circumstances.

 All that is necessary for due process is that the process be tailored to the capacitites and
circumstances of those who are to be heard to insure that they are given a meaningful
opportunity to present their claims.
 And here, where the prescribed procedures not only provide the claimant with an effective
process for asserting his claim prior to any administrative action, but also assure a right to
an evidentiary hearing, as well as subsequent judicial review before the denial of his claim
becomes final, there is no deprivation of procedural due process.

DECISION.
Petition DISMISSED.