Goldberg v. Kelly
Goldberg v. Kelly is a landmark Supreme Court case decided in 1970 that addressed the due process rights of public assistance recipients. The case arose when New York welfare officials terminated the assistance of a recipient, allowing for a challenge only after the termination had occurred. In a narrow 5-4 ruling, the Court determined that due process requires a pretermination hearing for beneficiaries, emphasizing that welfare entitlements function as a form of property essential for survival and community participation. Justice William J. Brennan, Jr. highlighted that recipients should have the opportunity to confront witnesses, retain legal counsel, and present oral evidence to an impartial official. This ruling underscored the importance of procedural safeguards for vulnerable populations. Subsequently, the principles established in Goldberg v. Kelly were extended in later cases, reinforcing the need for due process in various contexts, including education and disability benefits. Overall, this case has had a significant impact on the legal landscape surrounding welfare rights and due process in the United States.
Goldberg v. Kelly
Date: March 23, 1970
Citation: 397 U.S. 254
Issue: Due process
Significance: The Supreme Court held that the due process clause of the Fourteenth Amendment requires that state agencies must provide welfare recipients with evidentiary hearings before ending their benefits.
In conformity with state law, New York welfare officials terminated the public assistance of a recipient, with notice that the action could be challenged in a posttermination hearing. By a 5-4 vote, the Supreme Court held that a recipient must have the right to a pretermination hearing. Although not requiring the hearing to be a formal judicial proceeding, Justice William J. Brennan, Jr.’s majority opinion did specify that the recipient must be allowed to confront witnesses, to retain a lawyer, and to bring oral evidence before an impartial official. Brennan reasoned that a statutory entitlement to welfare was a form of property that helped poor people to survive and participate in the life of the community.
In subsequent decisions, the Court expanded the Goldberg principle to related situations. In Gross v. Lopez (1975), for example, the Court held that suspension of students from public schools constituted deprivation of property within the meaning of the Fourteenth Amendment. In Mathews v. Eldridge (1976), however, the Court shifted toward a balancing test when it approved of a policy of not providing opportunity for a hearing for recipients of Social Security disability payments before termination of benefits.