Supreme Court - Goldberg v Kelly - Research Paper Example

? Running Head: Supreme Court Cases Supreme Court Cases In the case of Goldberg v Kelly, the Supreme Court established doctrinal teaching on the constitutional mandates of procedural due process, to the effect that an individual is entitled to the twin requisites of due notice and hearing before an administrative decision be made against him that seriously and adversely affects his means of subsistence. This observance of this constitutional right gains greater significance if the government interest sought to be served by the administrative decision is lacking in urgency and importance. In this discussion, a brief account of the facts of the case is presented, followed by a discussion of the qualification of the case for judicial review pursuant to the ripeness, standing, exhaustion of remedies, and primary jurisdiction. The administrative action taken in this case, which consisted of five steps, is described, after which a stand is made that the court’s action had no effect on any perceived arbitrariness in the administrative agency’s decision. This writer’s opinion was rendered on the appropriateness of the court’s decision, and foreseen future implications on administrative actions are briefly described. On the case of Goldberg v Kelly 1. Offer a brief summary/historical overview of the circumstances in the case, the stakeholders, and the outcome sought by the plaintiff. In this case, the appellants were New York state officials and the Commissioner of Social Services, New York City. The appellees are New York City residents who were receiving financial aid under federally supported Aid to Families with Dependent Children program, and the general Home Relief program of New York State (397 U.S. 256). Plaintiff-appellees allege that their benefits either have been or were about to be terminated by officials without prior notice and hearing. They claim in effect, denial of their constitutional right to be afforded the due process of law, for which they sought the restoration of their welfare benefits pending results of evidentiary hearing where they could present their case (397 U.S. 256-257). Upon conclusion of the administrative procedure and remedies during which time plaintiffs’ welfare benefits were terminated, action was brought by the aggrieved party in the District Court for the Southern District of New York. Defendants argued that pursuant to regulation, a pre-termination review was conducted at the end of which it was decided that termination of benefits was warranted. At this juncture, the benefits were halted, although plaintiffs were afforded the option of requesting for a post-termination “fair hearing” during which they may appear personally before the decision-maker, adduce their evidence and confront and cross-examine the witnesses against them. The rationale behind the discontinuance of welfare benefits after the administrative review and summary adjudication prior to the “fair hearing” was purportedly to protect the interests of the New York taxpayer, in case the hearing finds the discontinuance to be meritorious (397 U.S. 265). The district court ruled in favor of plaintiffs, that in light of the constitutional mandate, a pre-termination evidentiary hearing is required in order to satisfy the due process requisite under the law (397 U.S. 256-257). The District Court rejected the argument by welfare officials that their conduct of a post-termination “fair hearing” as well as an informal pre-termination review had adequately complied with the law. The decision of the District Court was withheld on appeal. 2. Explain how the case qualified for judicial review in regards to the ripeness, standing, the exhaustion of administrative remedies, and primary jurisdiction as they apply. The doctrine of ripeness is concerned with whether at the time a judicial action is brought, the facts have sufficiently developed such that the injury has occurred or is likely to occur, instead of being remote or contingent. A claim is ripe if the injury upon which it is based is imminent, direct and immediate. If the claim were still remote or hypothetical, then the resulting adjudication or opinion of the court may prove premature; only if the injury has occurred or is imminent and concrete can a right of claim be determined by the court. Together with the mootness doctrine, the ripeness doctrine examines the problem of justiciability from the perspective of time (May & Ides, 2007, p. 135). The standing doctrine is a doctrine articulated by the court which seeks to ensure that the plaintiff is the proper party to bring a claim in court (Ho & Ross, 2009). Standing (locus standi) refers to the party’s connection to the case, or has suffered harm from it, in order to justify his/her participation in the court proceeding. In this case, the recipient of the aid, herein plaintiff, is deemed the proper party to elevate the case to the judicial process, because it is the recipient who has suffered the harm of lost income and discontinuance of the source of his subsistence by the termination of the financial aid. The doctrine of exhaustion of administrative remedies applies where a claim is initially cognizable in the first instance by an administrative agency alone. The interference of the courts is withheld pending the completion of the administrative process. The final resolution of the administrative agency hearing the case constitutes the cause of action and is a condition precedent before judicial action may be filed (Lockwood, 2007: 741). It is well a well-established principle in jurisprudence that in general, a party must first exhaust all available administrative remedies before bringing an action challenging a decision of a government agency (Wells & Eaton, 2002: 218). The doctrine of primary jurisdiction states that where an action is concurrently within the jurisdiction of the court and an administrative agency, but the determination of the case necessitates the technical expertise of the administrative agency, then the court yields to the prior determination of the administrative agency before it assumes jurisdiction of the case (Lockwood, 2007: 708). All these three doctrines are analogous to each other, although each is concerned with a different aspect of the case. The principal aim in all three doctrines is the protection of the power of the administrative agency and the improvement of efficiency in the courts (Lockwood, 2007: 741). In Goldberg v Kelly, the case may be considered justiciable under the ripeness doctrine because the injury that is the basis of the claim – the termination of financial aid – has already taken place and the plaintiff is thereby already suffering from being deprived of this benefit. The case may also be considered ready for judicial determination because administrative remedies had already been exhausted. From the initial notice by the caseworker until the post-termination “fair hearing”, all the prescribed administrative remedies have been taken, and the final step allows for recourse to the courts. The same may be said for the case under the doctrine of primary jurisdiction; the expertise of the agency has already been applied in the prior determination, which paves the way for court to assume jurisdiction. 3. If available, highlight the administrative action that took place in the case. The administrative action in this case involves the following procedure: (1) The administrative action commences with a motu propio (“on his own impulse”) action on the part of a caseworker who doubts a recipient’s continued eligibility to receive financial aid. The caseworker’s first course of action is to discuss his doubts with the recipient. If after the consultation the caseworker concludes that the recipient is no longer eligible, he recommends to his unit supervisor that aid be terminated (397 U.S. 258-259). (2) If the unit supervisor agrees with the findings of the caseworker, the supervisor sends the recipient a letter informing him of the proposed termination of aid and notifying him that he has the right to exercise, within seven days, to request that a higher official review the record. The request should be prepared in written form, by the recipient personally or with the assistance of counsel or other person (397 U.S. 259). (3) The reviewing superior official then makes his own determination, and if he concurs with the unit supervisor’s assessment then aid is immediately discontinued, and the recipient is informed in writing concerning the reasons for the action. (4) After the aid has been terminated, the recipient may still request for a post-termination “fair hearing”, although the letter informing him of the decision to terminate his aid fails to inform him of this (397 U.S. 259). The “fair hearing” is a proceeding before an independent state hearing officer during which time the recipient may at last personally appear. The recipient is afforded the chance to afford oral evidence and to confront and cross-examine witnesses against him, and have the hearing made a matter of record. (5) After the “fair hearing”, if the findings are once more against him, only then may the recipient elevate his case for judicial review. The conclusion of the “fair hearing” and the notification of the recipient about its decision ends the administrative proceeding, at which point the recipient may resort to judicial remedies. 4. Address whether or not the court succeeded or failed in reducing arbitrariness. The court may reduce arbitrariness if it sets out doctrinal principles which would better guide the future decisions arrived at by administrative agencies in the discharge of quasi-judicial functions. An arbitrary decision is one that does not squarely proceed from the facts and law of the case, but exhibits an excess or abuse of discretion. The arbitrary and capricious test applied to agency decisions requires that: (1) The decision be “based on a consideration of the relevant factors,” including the alternatives to the agency’s proposal suggested by the record; (2) The decision does not suffer from “a clear error of judgment”; (3) The decision should be made under the correct legal standard; and (4) The decision is supported by a satisfactory explanation for [their] action including “a rational connection between the facts found and the choice made.” (Beerman, 2010: 69). In this case, the court neither succeeded nor failed in reducing arbitrariness, because what was at question was the constitutionality of the administrative procedure the agency pursued, not the merits of the decision it arrived at. The quality of the decision of the agency was not at question, and no controversy was raised concerning any alleged abuse of discretion. The issue was a constitutional question as to “whether the Due Process Clause requires that the recipient be afforded an evidentiary hearing before the termination of benefits” (397 U.S. 260). The subsequent ruling was therefore on the procedure, not substance, of the agency’s decision. 5. Do you agree with the majority opinion of the Supreme Court? I agree with the majority opinion expressed by the Supreme Court, as penned by Mr. Justice Brennan, that the procedure followed by the administrative agency was in violation of the Due Process Clause. The court’s decision corrected the inherent injustice that is imposed against the recipients of financial aid, as a result of an administrative procedure that deprived the recipients of a statutory right by summary judgment. The constitutional right to due process mandates that a person be afforded the twin requisites of notice and hearing before he is deprived of his property. To the question as to whether the benefit enjoyed is not property but a privilege that may be taken away, the court ruled that certain government entitlement that are in the nature of welfare benefits are considered entitlements for which the recipients have a property interest. The beneficiaries of the financial assistance were poor and destitute, and need the aid for their sustenance – no need can be greater or more exigent. Furthermore, the pre-termination remedy allowed the recipient to present his case only in writing; this is tantamount to denying such recipient a hearing, since persons who avail of this aid are seldom educated enough to effectively put their case forward in writing, and too poor to hire an attorney to do it for them. Furthermore, the recipients did not have the opportunity to present their evidence and confront the witnesses who gave adverse testimony against them, effectively denying them the right to examine and refute the allegations against them. The remedies in place in the administrative procedure prescribed were clearly not sufficient to afford the recipient the twin requisites of notice and hearing. The Supreme Court is likewise justified in affirming the lower court’s opinion that no less than a pre-termination evidentiary hearing could remedy the constitutional infirmity of the administrative procedure in this case. Because the violation is procedural rather than substantial, the decision arrived at during the administrative procedure is untenable. The recourse is to restore the entitlement to the recipient and to repeat the process if warranted, but to ensure that prior to the curtailment of the financial aid to the recipient, notice should be given him detailing the basis of the assessment that he is no longer eligible for the aid, and an evidentiary hearing should be afforded the recipient to orally testify and to confront the witnesses against him. 6. What are the implications for future administrative actions? The implication of this decision is that future administrative actions should distinguish between regular benefits and those that are in the nature of welfare benefits. The distinction should rest, as the decision stated, on the severity of the injury to the recipient based on his reliance on said benefit for subsistence and the basics of life. The pre-termination evidentiary hearing should be made to apply mandatorily only to those cases where the benefit may be considered within the ambit of a property entitlement; while such may be applied also in the case where the right to the benefit is not equivalent to a property right, it is not mandatory as a constitutional guarantee. Another implication is that future administrative actions should take into consideration the injury to those deprived and give it precedence over the pecuniary setback to the government, where the human dilemma is tantamount to a “grievous loss” (397 U. S. 263). References Beermann, J. M. (2010) Administrative Law. New York, NY: Aspen Publishers Goldberg v Kelly (1970) Supreme Court Cases: The Dynamic Court (1930-1999), 1999 Harrington, C. B., & Carter, L. H. (2009). Administrative Law and Politics: Cases and Comments (4th ed.). Washington, DC: CQ Press. ISBN: 9780872899346 Ho, D.E. & Ross, E.L. (2009) “Did Liberal Justices Invent the Standing Doctrine? An Empirical Study of the Evolution of Standing, 1921-2006”. Standford Law School. Accessed from http://webcast-law.uchicago.edu/pdfs/PEPLho.pdf Lockwood, A J (2007) “Primary Jurisdiction Doctrine: Competing Standards of Appellate Review”. Washington & Lee Law Review, 64:707-751. Available at http://law.wlu.edu/deptimages/Law%20Review/64-2LockwoodNote.pdf Macon, C (2010) “A Research Guide to Procedural Due Process Rights of Public Assistance Beneficiaries.” Available at http://slu.edu/Documents/law/Academics/Candice_Macon_ALRPathfinder.pdf May, C. N, & Ides, A. (2007) Constitutional Law: Individual Rights, 4th edition. New York, NY: Aspen Publishers Read More