Goldberg v. Kelly Case Brief Summary | Law Case Explained

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Goldberg v. Kelly | 397 U.S. 254 (1970)

Some people’s income is insufficient to get by on, so they need public assistance. What happens if government officials decide to revoke the benefits because they believe the recipients are no longer eligible to receive them? Can they do so without first providing the recipients a chance to prove their continuing eligibility at a hearing? The United States Supreme Court addressed this issue in Goldberg versus Kelly.

Based on his lack of sufficient income and assets, the New York City Department of Social Services granted John Kelly public assistance to meet his basic needs. Regulations required a caseworker to periodically investigate Kelly after he began receiving benefits in order to determine his continuing eligibility. One day, without any prior notice, Kelly received a letter from the Department informing him that he no longer was entitled to benefits based on the caseworker’s findings.

Kelly and others who also had their public assistance abruptly cut off filed a class-action lawsuit against Jack Goldberg, the New York City Commissioner of Social Services, as well as related state officials, in federal district court. The plaintiffs contended that the Department’s decision to abruptly terminate their public assistance without prior notice and a hearing violated the Due Process Clause of the Fourteenth Amendment.

During the course of the litigation, the Department modified its procedures to require prior notice before termination of public assistance and the recipients’ right to respond in writing. In addition, the modified procedures provided that a person whose benefits were terminated could have a post-termination hearing before an administrative hearing officer. However, the modified procedures still didn’t require a pre-termination hearing at which the recipient at risk of losing the benefits could appear in person before a hearing officer.

A three-judge panel of the district court ruled in favor the plaintiffs, concluding that the modified procedures were constitutionally inadequate.

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