Mathews v. Eldridge, 424 U.S. 319, 1 Cal. Comp. Cases 920, 47 L. Ed. 2d 18 (1976)
Facts
Eldridge received disability benefits for a few years under the Social Security Administration. He received a questionnaire from the state agency, and completed it stating that his condition had not gotten better. The agency reviewed his file and reports from his doctor, and concluded that his disability had ceased. The agency notified Eldridge, and advised him to request additional time to collect more information in accordance to his condition. Eldridge responded by contending one of his medical characterizations was enough confirmation for the agency to determine that his disability should be covered. Even with Eldridge’s response, the agency came to the conclusion that his disability had ceased, and his benefits would be taken away by the end of the month. The agency informed him that he could seek reevaluation of his case in six months.
Eldridge responded to this by challenging the agency claiming that it was unconstitutional to terminate his disability benefits without having a hearing. The court relied heavily on the case Goldberg v. Kelly, and ruled that the termination of Eldridge’s disability benefits was a violation of the procedural due process. This was affirmed by the Court of Appeals that Eldridge was entitled to evidentiary hearing under Title IV of the welfares beneficiary act. This decision was later repealed by the supreme court.
Issue
1. Does the due process clause of the Fifth Amendment require a hearing of the social security disability recipient before the discontinuation of his benefits?
Decision
1. No, it does not require a hearing before, because it did not coincide with the three factors of the due process test. 1) Eldridge’s private interest was not interrupted because the eligibility for Social Security benefits are not based on financial need, but rather on their disability. 2) The procedure used to determine Eldridge’s disability was based off of medical documents and a standard procedure. 3) Lastly, it would be an economic burden to implement a hearing for each disability recipient who is considered no longer qualified.
Reasoning
The supreme court used the due process clause of the Fifth Amendment in their reasoning and decision for Eldridge’s case. In the first test to see if applies to the due process they looked at whether or not it affected the private interest by the action. The court interpreted Eldridge’s private interest was to inquire Social Security benefits due to his disability, not because of financial means. They compared it to the Goldberg case in their reasoning that even though his need for disability might be significant it still was less than a welfare recipient in relation to a financial standpoint. Therefore, if Eldridge’s private resources did decline due to not having disability benefits there are other government assistance that are available.
The court then looked at the second test to see if they followed a standard and organized procedure. The procedure to discontinue the disability benefits was standard and routine medical reports by physicians. When looking at the reports they recognized the fact that medical professionals can have disagreements on the conclusions therefore leading to error. The questionnaire that was distributed to the recipients gives them the option to get assistance from the Social Security Act office. This allows them the ability to have more substantial evidence such as X-rays and lab results instead of a written presentation. The court reasoned that Eldridge had all these resources and straight foreword procedures provided that were necessary that he didn’t utilize.
Lastly, the court looked at the third test to see if it would be a financial burden and additional procedural requirements. If every ineligible recipient was given a hearing it would increase the number of hearings substantially, causing a great economic burden overall. They reasoned that by giving these hearing to the ineligible recipients it would cause more harm than good by taking away from the public people who were deserving of it.
Analysis
I believe that the supreme court’s ruling was correct, and substantial in providing a guideline for future cases like this one. When they were making their decision they made sure to go through every part of the due process and rule out why Eldridge’s case didn’t qualify. By doing this I think it was clear that the cons outweighed the pros not only financially but also for the overall public. Eldridge was also provided with other options such as government assistance if needed if his financial stance was below the welfare line due to his disability benefits being terminated. This showed that even with the termination he would still be taken care of financially. Also, Eldridge’s proof of his disability was through a medical report from his physician, but didn’t contain any hard evidence such as an X-ray or lab results etc. This led me to believe that one doctors opinion may not be exactly right, and there needs to be concrete proof. Overall, because all of the steps were taken in Eldridge’s case and each one failed the due process it is clear that the supreme court ruling was correct.
Molargik v. West Enterprises, Inc., Ind. App., 605 N.E.2d 1197 (1993)
Facts
The Molargik’s were replacing some of their land that had previously had peat moss with dirt. This process required the moss to be removed, and dump trucks to come in with the necessary means of dirt for the area, and be stored on the property till use. West owned a car company near Molargik’s property, and filed a complaint against them due to the excess dirt causing damages and injunctive relief. The Molargik’s responded by denying the majority of the complains, and didn’t specifically plead any defenses.
In Molargik’s opening statement they referred to Ind. Code 43-1-52-4 protecting prior existing industrial operations from being nuisances, but they failed to give this response as their original defense. West objected their opening statement stating that the Molargik’s had failed to raise this defense that is required by Trial Rule 8©. West Enterprise also contended that Molargik’s use of Ind. Code 43-1-52-4 wasn’t valid due to Molargik’s operation isn’t deemed an industrial operation, and had to be pleaded under Trial Rule 8 ©.
Issues
1. Did the Molargik’s relinquish their dispute that they were protected under the Ind. Code 43-1-52-4 due to their failure to affirmatively plead that law as a defense?
2. Were the trial courts finding of 50% of West’s damages from the Molargik’s property clearly erroneous?
Decision
1. Yes, because the Molargik’s didn’t previously request to be allowed to amend the pleadings, intern the court never did so. The pleadings were never amended, and the Molargik’s defense is denied under Ind. Code 43-1-52-4 due to failure of pleading.
2. No, because the trial court determined the percent on different evidentiary factors such as land proximity, other possible dirt sources, and the dryness of Molargik’s compared to other properties.
Reasoning
The court’s reasoning on these decisions relied on the fact that the Molargik’s did not request for any of their pleadings to be amended. Under the Trial Rule 8 © Molargik’s would have had to provided their defense when responding to West’s complaints. Overall, the court decided not to take into consideration Molargik’s indication in their opening statement due to them attempting to produce evidence on the defense that they had not previously requested, thus they were never amended.
When going over the percentage of damages caused by the Molargik’s to the West’s the court looked at numerous different factors. When receiving testimonies from witnesses it came into question if all the dirt came from the Molargik’s property or nearby properties. The court took into consideration the proximity of the different properties with dirt as well as the Molargik’s when making the decision. This accompanied with looking at the amount of dirt and the state that it was in on the property helped determine the court’s reasoning. Since the dirt was dry and stored in piles it was more likely that the Molargik’s dirt was the cause of the damages. The court affirmed the previous decision.
Analysis
I believe in this situation that the court got it right, because of the evidence that was taken into consideration, and the fact that the Molargik’s failed to amend their pleading in a timely manner. The Molargik’s failed to use their defense and reply to West’s complaint, and then didn’t plead the evidence in a timely manner resulting in their defense not being valid under Trial Rule 8 ©. This could have been easily avoided if the Molargik’s would have followed the procedure and gotten their evidence and defense in on a timely matter. This way the Molargik’s could have used the defense of Ind. Code 43-1-52-4. Also, the fact that the Molargik’s dirt was dryer and in piles making it more susceptible to blown onto the West’s property also leads me to believe that they are at fault. Overall, I think the Molargik’s handled this case poorly, and would have had a better chance if they had followed the trial rules and got their defense in at a timely manner.