Wheeler v. Montgomery

Background

This case was brought by people receiving California old-age welfare benefits who challenged the State’s practice for stopping payments. California’s rules required written notice at least three days before a payment stop, reasons for the action, a statement of what was needed to regain eligibility, and an offer to meet a caseworker informally. The State did not provide a formal oral evidence hearing where a recipient could present witnesses or cross-examine opposing witnesses.

Reasoning

The central question was whether due process requires a formal evidentiary hearing before welfare payments can be cut off. The Supreme Court decided—on the authority of its companion decision in Goldberg v. Kelly—that procedural due process does require such an oral, evidentiary pre-termination hearing. Because California’s procedure lacked that kind of hearing, the Court reversed the lower court’s judgment and found the procedure insufficient.

Real world impact

As a result, state and local agencies that stop welfare payments must provide recipients an opportunity for an evidentiary oral hearing before benefits are discontinued or suspended. The ruling affects California old-age benefit recipients directly and may require other jurisdictions to change their procedures. The decision may increase administrative workloads and delay some terminations while hearings are provided.

Dissents or concurrances

Justices Burger (joined by Justice Black) and Stewart dissented, warning that administrative agencies and new federal regulations were already moving toward hearings, that the decision could be costly, and that courts should allow administrative solutions to develop before imposing a constitutional rule.