Goldberg v. Kelly
 | |
| Goldberg v. Kelly | |
| Term: 1969 | |
| Important Dates | |
| Argument: October 13, 1969 Decided: March 23, 1970 | |
| Outcome | |
| United States District Court for the Southern District of New York affirmed | |
| Majority | |
| William Brennan • William Douglas • John Harlan II • Byron White • Thurgood Marshall | |
| Dissenting | |
| Hugo Black • Potter Stewart • Chief Justice Warren Burger | |
Goldberg v. Kelly was a United States Supreme Court case that treated welfare benefits as a form of property. As such, the Court ruled that state and federal government agencies could only remove welfare benefits after a pre-termination hearing at which recipients could confront witnesses before an impartial adjudicator.[1]
The case was argued on October 13, 1969, and decided on March 23, 1970. The case came on appeal from the United States District Court for the Southern District of New York.[1]
Why it matters: The Supreme Court's ruling in Goldberg v. Kelly was the foundation of procedural due process, which is the idea that the Constitution requires state and federal governments to give notice and an opportunity to be heard before they act in such a way as to deny a citizen of an interest in life, liberty or property.[1][2]
You can review the lower court's opinion here.[3]
Background
| Administrative State |
|---|
|
| Five Pillars of the Administrative State |
| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
| Click here for more coverage of the administrative state on Ballotpedia |
Case background
New York City residents were receiving financial aid under the federally assisted Aid to Families with Dependent Children (AFDC) program. New York State officials allegedly terminated or were going to terminate the residents' benefits without notifying them beforehand or giving them a hearing. The beneficiaries sued claiming that without notice and a hearing they were losing their benefits contrary to due process of law.[1]
Panel opinion
The United States Supreme Court affirmed the United States District Court for the Southern District of New York. The lower court held that pre-termination hearings were required by the Constitution before welfare recipients could lose their benefits and that post-termination hearings were insufficient:[3]
| " | To sum up: We hold that a pre-termination hearing for welfare recipients is constitutionally required and that the procedures set forth above for such hearing are the constitutional minimum. Accordingly, we deny defendants' motion for summary judgment; we grant plaintiffs' motion for a preliminary injunction as to the operation of option (b), and deny it as to option (a), for the reasons and on the conditions stated herein. In addition, nothing herein is meant to affect the right to a post-termination hearing in accordance with the procedures already in existence.[3][4][5] | ” |
Question presented
| Question presented: "[W]hether the Due Process Clause requires that the recipient be afforded an evidentiary hearing before the termination of benefits."[1] |
Audio
- You can find audio of the oral argument here.
Decision
The Supreme Court held 5-3 to affirm decision of the United States District Court for the Southern District of New York. The majority opinion was written by William Brennan and joined by Justices William Douglas, John Harlan II, Byron White and Thurgood Marshall. Chief Justice Warren Burger, and Justices Hugo Black and Potter Stewart filed separate dissenting opinions.[6]
Opinions
Opinion of the court
The majority held that only a pre-termination evidentiary hearing provides welfare recipients with procedural due process as required by the Constitution. The Court said:[1]
| " | For qualified recipients, welfare provides the means to obtain essential food, clothing, housing, and medical care. Thus, the crucial factor in this context -- a factor not present in the case of the blacklisted government contractor, the discharged government employee, the taxpayer denied a tax exemption, or virtually anyone else whose governmental entitlements are ended -- is that termination of aid pending resolution of a controversy over eligibility may deprive an eligible recipient of the very means by which to live while he waits. Since he lacks independent resources, his situation becomes immediately desperate. His need to concentrate upon finding the means for daily subsistence, in turn, adversely affects his ability to seek redress from the welfare bureaucracy.
Moreover, important governmental interests are promoted by affording recipients a pre-termination evidentiary hearing. From its founding, the Nation's basic commitment has been to foster the dignity and wellbeing of all persons within its borders. We have come to recognize that forces not within the control of the poor contribute to their poverty. This perception, against the background of our traditions, has significantly influenced the development of the contemporary public assistance system. Welfare, by meeting the basic demands of subsistence, can help bring within the reach of the poor the same opportunities that are available to others to participate meaningfully in the life of the community. At the same time, welfare guards against the societal malaise that may flow from a widespread sense of unjustified frustration and insecurity. Public assistance, then, is not mere charity, but a means to "promote the general Welfare, and secure the Blessings of Liberty to ourselves and our Posterity." The same governmental interests that counsel the provision of welfare, counsel as well its uninterrupted provision to those eligible to receive it; pre-termination evidentiary hearings are indispensable to that end.[1][7][5] |
” |
The Court also found the hearings implemented by New York to be deficient because they did not allow for welfare beneficiaries to present evidence, to be heard by themselves or through a lawyer or to cross-examine witnesses.[6]
You can find the full-text of the opinion here.
Dissenting opinions
Justice Hugo Black filed an opinion dissenting from the judgment. Black believed the Court was going beyond what he saw as its role to interpret the Constitution into usurping the legislative powers of Congress and the people. He reasoned:[1]
| " | It somewhat strains credulity to say that the government's promise of charity to an individual is property belonging to that individual when the government denies that the individual is honestly entitled to receive such a payment.
I would have little, if any, objection to the majority's decision in this case if it were written as the report of the House Committee on Education and Labor, but as an opinion ostensibly resting on the language of the Constitution I find it woefully deficient. Once the verbiage is pared away it is obvious that this Court today adopts the views of the District Court "that to cut off a welfare recipient in the face of . . . 'brutal need' without a prior hearing of some sort is unconscionable," and therefore, says the Court, unconstitutional. The majority reaches this result by a process of weighing "the recipient's interest in avoiding" the termination of welfare benefits against "the governmental interest in summary adjudication." Today's balancing act requires a "pre-termination evidentiary hearing," yet there is nothing that indicates what tomorrow's balance will be. Although the majority attempts to bolster its decision with limited quotations from prior cases, it is obvious that today's result does not depend on the language of the Constitution itself or the principles of other decisions, but solely on the collective judgment of the majority as to what would be a fair and humane procedure in this case.[1][8][5] |
” |
Chief Justice Warren Burger filed a dissenting opinion joined by Justice Black. He argued that the Court should not have intervened to engage "in 'legislating' via constitutional fiat when an apparently reasonable result has been accomplished administratively." He cited regulations that would require even stricter procedures than those outlined by the majority.[9]
Justice Potter Stewart filed a dissenting opinion saying that the question was close, but that the procedures used to terminate welfare payments did not violate the Constitution.[9]
See also
Footnotes
- ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 United States Supreme Court, Goldberg v. Kelly March 23, 1970
- ↑ Cornell Law School, "Procedural due process," accessed August 23, 2018
- ↑ 3.0 3.1 3.2 U.S. District Court for the Southern District of New York, Kelly v. Wyman, November 26, 1968
- ↑ Internal citations and quotations have been omitted.
- ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 6.0 6.1 Oyez, Goldberg v. Kelly, accessed August 23, 2018
- ↑ Internal citations and quotations have been omitted.
- ↑ Internal citations and quotations have been omitted.
- ↑ 9.0 9.1 United States Supreme Court, Wheeler v. Montgomery, March 23, 1970
| |||||||||||||||||||||||||
| |||||||||||
