Mathews v. Eldridge, 424 U.S. 319, 96 S. Ct. 893, 47 L. Ed. 2d 18 (1976)
Facts
The worker in this case (Eldridge) was receiving Social Security disabilities benefits. These are benefits that are given to injured people that are not capable of working and making money because of certain health problems they may have, that impede them from working. He received something that looked like a survey or questionnaire and completed it, as he was told. When he sent it back, the state agency that was on this case reviewed the information answered and other reports from doctors. After reviewing the information, they sent him a letter telling him that they had made a decision and his Social Security disability benefits were coming to an end; therefore, he would no longer receive them. They sent him a statement of reasons as to why this was happening and they allowed him to request more time so he could send more information about his condition, if he still needed the benefits. He responded, and only stated one description of his illness/condition and stated that the state agency already had the information needed to determine his eligibility for Social Security disability benefits. The state agency on this case then made their final decision and told the respondent (Eldridge) that he was no longer eligible for Social Security disability benefits, and that they would be taken away from him by the end of the month. Eldridge filed a suit, stating that his disability benefits could not be taken away before a hearing had taken place. The District court stated that he had the right to a hearing before the termination, because it violated procedural due process under the Title V act, and the Court of Appeals affirmed this decision, stating that a hearing was to take place before the termination of his disability benefits.
Issues
1. Was the Due Process Clause of the Fifth Amendment violated when the SSA terminated Eldridge’s Social Security disability benefits before giving him a hearing?
Decision
1. No. Eldridge seemed to be using the benefits for his own interest, because what was used to determine whether he was still eligible were unbiased medical examinations, which clearly shows if he is in better condition and still eligible to receive benefits. Even with large loads of other information, it would be useless as medical records do not lie.
Reasoning
The information that was used to determine Eldridge’s termination of disability benefits were medical records that were kept, and this is straightforward information that showed that he was no longer ill or injured even though they gave him the option to add more medical examinations that proved he was ill, but he did not; therefore, he did not have to be awarded Social Security Disability benefits. Also, the court decided that this was not related to the Goldberg case because it was not related to being financially poor. The court stated that someone who is denied disability benefits can still go find an easy job that will support them, but people who are actually impoverished and denied welfare are less likely to be able to find a way of income.
The court also stated that the high costs that would come from a hearing, of someone that in the end is not actually eligible, could be money that they could have used to give those impoverished people. Going to court for a hearing would have lowered the amount of money given to people that were without a doubt eligible to receive welfare or disability benefits. Based on all of the information given, the court reversed the decision of the lower district court, and stated that a hearing was not required before the disability benefits of Eldridge were terminated.
Analysis
I believe that the final decision on this issue was the correct thing to do. Eldridge was given the option to ask for time and enter more physical examinations to show the court that he was eligible, but he didn’t; therefore, because of medical records that the state agency had ahold of they could make the decision that he was actually no longer eligible. The money that they were given to him, they could have been using to give to someone with lower income that was denied welfare, or someone who is really disabled and can’t work. The amount of costs associated with going to court for a hearing, just to determine that he was not eligible would have been a waste of money, when they had all the information necessary to realize that he was no longer eligible to be receiving these benefits. I believe that the court made a great decision by reversing the decision of the lower court, and stating that a hearing was not required, the due process of the fifth amendment was not violated.
Molargik v. West Enterprises, 605 N.E.2d 1197, 1993 Ind. App. LEXIS 12.
Facts
The Molargiks bought land in front of West Enterprises. When they bought the land, it had moss in it, and it was a very wet piece of land. They removed the moss by digging holes in areas that contained this mossy substance, and they were going to fill the holes with fine brown dirt. The fine brown dirt was transported to their land in large dump trucks and it was stored in piles on their land, while they were able to fill the holes with the fine brown dirt. West Enterprises serviced new and used vehicles at their dealership, which was located across the street from the Molargiks’ property. The West Enterprise dealership filed a complaint against the Molargik’s, stating that their property caused a nuisance to their dealership, as they were spending more money to clean the cars from the dirt that blew from the Molargiks’ proprety. The Molargik’s responded and denied the allegations put forth by West Enterprises; however, they failed to insert I.C. 34-1-52-4, in their answer, which is required by Trial Rule 8(C), but attempted to use it in their opening statement in trial court, and West Enterprises pointed that out. The Molargiks’ failure to plead their use of I.C. 34-1-52-4 in their answer, they waived the possibility of using this in court. They then contested that there was no evidence that they caused 50% of the dirt-related damages for West Enterprises; however, the court no longer re-evaluated their evidence since the Molargiks’ dirt was in piles on their property, and they affirmed the case, and West Enterprises won.
Issues
1. Was the state’s determination that the dirt from the Molargiks’ property is what caused more than 50% of damages for West Enterprises wrong or did they do it to save time?
2. Were the Molargik’s really not protected by I.C. 34-1-52-4 because they did not state that in their answer to the complaint?
Decision
1. No. There was sufficient evidence to state that some of the damage may have come from the Molargiks’ property; however, there is no way of knowing how much damage actually came from the Molargiks’ property.
2. No. The court only had the Plaintiff’s proof and he stated that it was a nuisance, but that was not enough to prove that statute created an affirmative defense, and if West Enterprises was an industrial operation it could not constitute this act as a nuisance.
Reasoning
The state of Indiana laws uses I.C. 34-1-52-4 to protect existing industrial operations from being considered as nuisances; however, it is not stated that this I.C. cannot be used as an affirmative defense for the party. State of Indiana law clearly states in Trial Rule 8(c) that this I.C. cannot be used as an affirmative defense if it is not written in their responsive pleadings, if not clearly stated in their response it will be waivered.
For an affirmative defense to be considered in the State of Indiana it has to controvert something stated in the Prima Facie case of the Plaintiff, that conducted the complaint. It must be requested to amend a pleading before an affirmative defense is attempted to be used in court, or the court will waive the defendant’s ability to amend their affirmative defense, and they will no longer be able to use it in court.
Analysis
I believe that the final ruling of this case was not correct. Yes, the Molargik’s waived their ability to use I.C. 34-1-52-4 in their defense because they failed to add this in their responsive pleading; however, there was not enough evidence to clearly identify that more than fifty percent of dirt, that caused damages and further expenses for West Enterprises, mostly came from the Molargiks’ property. Even though, it is highly possible that some of the dirt residue came from the Molargiks’ property, the amount of dirt that came from their property is not able to be calculated; therefore, they cannot make an assumption that more than fifty percent came from their property, especially if there are more areas that contain dirt around the West Enterprise dealership. I believe the court made the incorrect decision in this case, because they had no concrete evidence that all the dirt came from one specific spot because it would be almost impossible to know exactly where the dirt came from; however, they affirmed the complaint that came from West Enterprises.