Due process, unlike some legal rules, is not a technical conception with a fixed content unrelated to time, place and circumstances. Due process is flexible and calls for such procedural protections as the particular situation demands. Accordingly, resolution of the issue whether the administrative procedures are constitutionally sufficient requires analysis of the governmental and private interests that are affected. More precisely, identification of the specific dictates of due process generally requires consideration of three distinct factors: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.
A worker was awarded cash benefits under a disability insurance benefits program in 1968. This program provided workers with income during periods in which they are completely disabled. Over the years, the state agency monitored his medical condition. During this period, the worker completed a 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. After considering these reports and other information in his file, however, the agency informed the worker by letter that it had made a tentative determination that his disability had ceased in May 1972. The determination was disputed because of one characterization of his medical condition and indicated that the agency already had enough evidence to establish his disability. Eventually, the worker was notified that his benefits would terminate after that month and was advised to seek reconsideration by the state agency. Instead of seeking reconsideration, he commenced this action challenging the constitutional validity of the administrative procedures established by the Secretary of Health, Education, and Welfare for assessing whether there exists a continuing disability. He contends that due process requires a right to an "evidentiary hearing" prior to termination of welfare benefits.
Does due process require that prior to the termination of Social Security disability benefit payments the recipient be afforded an opportunity for an evidentiary hearing?
The United States Supreme Court found that respondent had not been denied procedural due process when he was not granted an evidentiary hearing prior to termination of his Social Security disability benefit payments. The district court had jurisdiction over the suit, because respondent had presented his claims for review to both the district social security office and the regional office for reconsideration, and petitioner Secretary of Health, Education, and Welfare had accepted the termination through the Social Security Administration. Procedural due process had been satisfied because respondent was not in as dire a position as that of a typical welfare recipient, and because of the myriad procedural safeguards of the process, including an evidentiary hearing before the denial of the claim became final. The public interest in limiting the procedures available was significant, given the cost of additional procedures.