Citation: Goldberg v. Kelly, 397 U.S. 254, 90 S. Ct. 1011, 25 L. Ed. 2d 287 (1970)
Court: Supreme Court of the United States
Date Decided: 1970
Judges: The majority opinion was delivered by Justice Brennan. Justices Black, Stewart, and Chief Justice Burger dissented.
Goldberg v. Kelly, 397 U.S. 254 (1970), is a landmark case in the United States where the Supreme Court established the procedural due process requirements that must be afforded to recipients of welfare benefits prior to their termination.
The case addressed the constitutionality of terminating public assistance benefits without providing a pre-termination evidentiary hearing, thus shaping the future of how governmental agencies are required to deal with the deprivation of entitlement benefits under the Fourteenth Amendment.
In this case, the Supreme Court held that a hearing, at least minimal in form, must be granted before welfare benefits are terminated to ensure fairness and protect the due process rights of welfare recipients. This decision significantly impacted the administrative procedures involved in the termination of welfare benefits and reinforced the protection of individuals’ rights to a fair process when their essential means of support are at stake.
Facts of Goldberg v. Kelly
The case involved residents of New York City who were receiving financial assistance under the federally funded Aid to Families with Dependent Children (AFDC) program or the state-run New York Home Relief Program. The appellees, a group of welfare recipients, challenged the termination of their benefits, which occurred without notice or a pre-termination hearing. They alleged that this denial of a hearing violated their constitutional right to due process under the Fourteenth Amendment.
The New York City welfare administrators had terminated the benefits of the appellees without prior hearings, leaving these individuals without essential financial support. After the lawsuit was filed, New York City amended its procedures to provide a notice and a hearing, but the plaintiffs challenged the adequacy of these revised procedures. Specifically, they objected to the lack of an opportunity for an oral hearing with cross-examination of witnesses, arguing that a mere written review did not meet constitutional due process standards.
The city’s process allowed the welfare recipient to contest the termination in writing, but it did not allow for an oral hearing where the recipient could personally present evidence or confront adverse witnesses. The District Court ruled that the state’s procedures were insufficient, emphasizing that only a pre-termination hearing could satisfy the constitutional requirements of due process.
Issues
The main legal questions presented to the Court in Goldberg v. Kelly were as follows:
- Does the Fourteenth Amendment require a hearing before the termination of statutorily defined welfare benefits?
- Does a pre-termination “informal hearing” satisfy the procedural due process requirements of the Fourteenth Amendment?
- Must the due process under the Fourteenth Amendment guarantee a full “evidentiary hearing” prior to the termination of welfare benefits?
- Does a welfare recipient have the right to counsel or an attorney at an evidentiary hearing regarding the termination of benefits?
- To what extent does the welfare administrative decision-maker need to be impartial in welfare hearings?
These questions sought to determine whether the termination of public assistance without a pre-termination hearing violated the constitutional rights of individuals receiving such assistance, and what procedural protections must be afforded to ensure that these individuals are not unfairly deprived of essential benefits.
Goldberg v. Kelly Judgment
The Supreme Court, in a 5-3 decision, ruled in favor of the appellees, affirming the lower court’s judgment. The Court held that the Due Process Clause of the Fourteenth Amendment requires a pre-termination evidentiary hearing before a recipient of welfare benefits can have their benefits taken away.
In delivering the opinion of the Court, Justice Brennan stated that welfare benefits were a form of “property” under the law and that individuals receiving such benefits had a legitimate entitlement to them. The Court concluded that due process demands that before such benefits are terminated, recipients must be given an opportunity to contest the termination in a fair and meaningful way. This means that recipients must be provided with an evidentiary hearing where they can confront adverse witnesses, present their own evidence, and argue their case.
The Court did not mandate a full judicial trial but required that the hearing be sufficiently formal to allow the recipient to challenge the basis for the termination. The Court emphasized that the decision-maker must be impartial and that the recipient should be informed of the reasons for the proposed termination in advance, ensuring that the decision is based solely on the evidence presented.
Justice Brennan’s opinion was in line with previous decisions that recognized government benefits, such as welfare, as entitlements that must be protected from arbitrary deprivation under the Fourteenth Amendment. The Court’s decision in Goldberg v. Kelly placed significant weight on the recipient’s need for uninterrupted access to welfare, which often provided vital support for basic necessities such as food, shelter, and healthcare.
The Court’s Reasoning in Goldberg v. Kelly
The Court’s reasoning in Goldberg v. Kelly centered on the idea that welfare benefits are more than just a government grant; they are a statutory entitlement for those who qualify. As entitlements, they carry with them certain protections, particularly the protection against arbitrary deprivation without due process of law.
The Court held that the loss of welfare benefits could have devastating consequences for recipients, particularly those in vulnerable socioeconomic positions. The Court cited the importance of ensuring that welfare recipients are not deprived of essential resources without the opportunity to contest the termination of their benefits. The Court explained that the procedural due process rights of recipients outweighed the state’s administrative and fiscal concerns, ruling that a fair process is essential to ensure that the termination of welfare benefits is not erroneous or unfair.
While the Court ruled that a full judicial trial was not necessary, it stated that the hearing must provide an opportunity for the recipient to present their case. This hearing must be conducted by an impartial decision-maker, and the recipient must be notified of the reasons for the termination in a timely manner. Although the Court did not mandate that an attorney be provided to the recipient, it held that the recipient must be allowed to hire an attorney if they wish.
Conclusion
In Goldberg v. Kelly, the Supreme Court addressed a critical question of constitutional law—whether due process protections extend to the termination of welfare benefits. The Court ruled that a pre-termination evidentiary hearing is required for welfare recipients, affirming that such benefits are a form of property that cannot be taken away without proper procedural safeguards.
The decision was pivotal in shaping welfare policy and ensuring that individuals receiving government benefits are afforded a fair opportunity to challenge the loss of their essential resources. Goldberg v. Kelly remains a cornerstone case in the area of procedural due process and continues to be cited in cases involving the deprivation of government benefits.