Facts

In Goldberg v. Kelly, the plaintiff-appellees were residents of New York City who were beneficiaries of financial aid that emanated from the federally assisted program of AFDC (Aid to Families with Dependent Children). The city officials were the respondents in the case. The plaintiff’s complaint was based on the fact that the city officials responsible for the administration of these programs had terminated the aid without giving the plaintiff prior notice and hearing. The plaintiff viewed this as a denial of procedural due process. The City had adopted procedures for hearing and notice, which the plaintiff-appellees later challenged as being constitutionally inadequate. The plaintiffs challenged the procedure for not according them the opportunity to present themselves before the cross-examination of adverse witnesses and reviewing officer for oral testimony. The district court held that a pre-termination hearing would only satisfy the constitutional due process requirement.

Issue

Does state’s termination of public aid benefits to the recipient without according them a hearing prior to termination violates the recipients’ procedural due process? Due process is an individual constitutional right issue as it is protected by the fifth and fourteenth amendments to the Constitution.

Rule

The legal requirement here is the due process. Welfare benefits are more of an issue of statutory entitlement for individuals that have qualified to receive them, and there is a need for the application of the procedural due process in their termination. The guiding principle here is that assistance should not be suspended or discontinued prior to the date when such notice regarding the decision is sent to the beneficiaries before the effective date of suspension or discontinuance.  There is also the need for assessing the adverse effects that might accrue to the recipients.

Application

Among the relevant questions to ask is whether the District Court involved with the case initially had followed the due process in its determination. The general rationale of the appeal court was that eligible recipients of public assistance that helps to provide essential basic needs, coupled with the state’s desire to ensure the payments are not erroneously terminated, tends to outweigh the State’s competing concern that revolves around preventing the increase to is administrative and fiscal burdens.

Conclusion

The court voted 5-3 in favor of the plaintiffs. It was held that the states ought to accord the public aid beneficiaries a pre-termination evidentiary hearing prior to discontinuing their aid.

Impact

The ruling had an impact on public administration in that it set a precedent in noting that welfare benefits are more of statutory entitlements rather than privileges. The conclusion that states’ interests in conserving costs are not sufficient in overriding aid beneficiaries’ interest in the procedural due process would set a precedent likely to impact public administration dealings.

 
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