Eldridge factors in Maine

7 Maine opinions name it 2 courts 1992–2021 1 in the last five years

The cases below were cited by Maine courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

Case	Followed	Cited
Fichter v. Board of Environmental Protectiongreen me · 1992 · cited in 2 Maine opinions naming this issue, 1996–1999 2 sentences 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian’s property interest in his professional license and his financial resources are at stake. 6 See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney’s license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me.1985) (due process prote 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian's property interest in his professional license and his financial resources are at stake. [6] See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney's license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me. 1985) (due process pr	2	2
Porter v. Hoffmangreen me · 1991 · cited in 2 Maine opinions naming this issue, 1992–1996 2 sentences 1996Protection, 604 A.2d 433, 437 (Me.1992) (applies Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection); Porter v. Hoffman, 592 A.2d 482, 487 (Me.1991) (applies Eldridge factors to due process challenge to adoption proceedings). 1992See also Porter v. Hoffman, 592 A.2d 482, 487 (Me.1991) (applies Eldridge factors to due process challenge of adoption proceedings); In re Charles Jason R., Jr., 572 A.2d 1080, 1081 (Me.1990) (applies Eldridge factors to challenged use of hearsay statements in child protection proceedings).	2	2
Hudson v. Palmergreen scotus · 1984 · cited in 1 Maine opinions naming this issue, 2014–2014 2 sentences 2014The Eldridge factors assess: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. /d. at~ 26 (citing Matthews v. Eldridge, 424 U.S. at 355). "[W]hile persons imprisoned for crime enjoy many protections of the Constitutio 2014The Eldridge factors assess: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. /d. at~ 26 (citing Matthews v. Eldridge, 424 U.S. at 355). "[W]hile persons imprisoned for crime enjoy many protections of the Constitutio	1	1
Board of Overseers of the Bar v. Lefebvregreen me · 1998 · cited in 1 Maine opinions naming this issue, 1999–1999 2 sentences 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian's property interest in his professional license and his financial resources are at stake. [6] See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney's license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me. 1985) (due process pr 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian's property interest in his professional license and his financial resources are at stake. [6] See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney's license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me. 1985) (due process pr	1	1
Appeal of Schrammgreen sd · 1987 · cited in 1 Maine opinions naming this issue, 1999–1999 2 sentences 1999See In re Appeal of Schramm, 414 N.W.2d 31, 35-36 (S.D.1987) (discussing rationale for due process protections in professional discipline proceedings). 1999See In re Appeal of Schramm, 414 N.W.2d 31, 35-36 (S.D.1987) (discussing rationale for due process protections in professional discipline proceedings).	1	1
Board of Registration in Medicine v. Fioricagreen me · 1985 · cited in 1 Maine opinions naming this issue, 1999–1999 2 sentences 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian’s property interest in his professional license and his financial resources are at stake. 6 See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney’s license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me.1985) (due process prote 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian's property interest in his professional license and his financial resources are at stake. [6] See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney's license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me. 1985) (due process pr	1	1
In Re Sabrina M.green me · 1983 · cited in 1 Maine opinions naming this issue, 1996–1996 2 sentences 1996In re Sabrina, 460 A.2d 1009, 1016 (Me.1983). 1996In re Sabrina, 460 A.2d 1009, 1016 (Me.1983).	1	1
In Re Charles Jason R., Jr.green me · 1990 · cited in 1 Maine opinions naming this issue, 1992–1992 2 sentences 1992See also Porter v. Hoffman, 592 A.2d 482, 487 (Me.1991) (applies Eldridge factors to due process challenge of adoption proceedings); In re Charles Jason R., Jr., 572 A.2d 1080, 1081 (Me.1990) (applies Eldridge factors to challenged use of hearsay statements in child protection proceedings). 1992The second factor, stated in other words, considers the “risk of error created by the State’s chosen procedure.” In re Charles Jason R., Jr., 572 A.2d at 1081 .	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Maine. Read the followed side critically anyway.

Also cited on this issue (5)

Case	Cited	Years
Balian v. Board of Licensure in Medicine green me · 1999 2 sentences 2021Under the second Eldridge factor, the Law Court held that: "in a Board comprised of both lay persons and persons of the regulated profession, the absence of a clear standard unduly shifts power and influence to the non-lay members." Balian, 1999 ME 8 , ! 13, 722 A.2d 364 . 2021Under the second Eldridge factor, the Law Court held that: "in a Board comprised of both lay persons and persons of the regulated profession, the absence of a clear standard unduly shifts power and influence to the non-lay members." Balian, 1999 ME 8 , ! 13, 722 A.2d 364 .	1	2021–2021
DaimlerChrysler v. EXEC. DIR., REV. SERVS. green me · 2007 2 sentences 2019Id. at~ 26. 2019Id. at~ 26.	1	2019–2019
Raynes v. Department of Corrections green me · 2010 2 sentences 2014The Eldridge factors assess: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. /d. at~ 26 (citing Matthews v. Eldridge, 424 U.S. at 355). "[W]hile persons imprisoned for crime enjoy many protections of the Constitutio 2014The Eldridge factors assess: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail. /d. at~ 26 (citing Matthews v. Eldridge, 424 U.S. at 355). "[W]hile persons imprisoned for crime enjoy many protections of the Constitutio	1	2014–2014
Mathews v. Eldridge green scotus · 1976 2 sentences 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian's property interest in his professional license and his financial resources are at stake. [6] See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney's license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me. 1985) (due process pr 1999Mathews v. Eldridge, 424 U.S. 319, 335 , 96 S.Ct. 893 , 47 L.Ed.2d 18 (1976); see also Fichter, 604 A.2d at 437 (Me.1992) (applying Eldridge factors to due process challenge to denial of permit by Board of Environmental Protection). [¶ 11] With respect to the first Eldridge factor, Balian's property interest in his professional license and his financial resources are at stake. [6] See Lefebvre, 1998 ME 24, ¶ 15 , 707 A.2d 69, 73 (due process protections implicated in hearing to suspend attorney's license); Board of Registration in Med. v. Fiorica, 488 A.2d 1371, 1375 (Me. 1985) (due process pr	1	1999–1999
Santosky v. Kramer green scotus · 1982 2 sentences 1996Santosky v. Kramer, 455 U.S. 745, 754 , 102 S.Ct. 1388, 1395 , 71 L.Ed.2d 599 (1982). 1996Santosky v. Kramer, 455 U.S. 745, 754 , 102 S.Ct. 1388, 1395 , 71 L.Ed.2d 599 (1982).	1	1996–1996

Where else courts name it

TX 66 (2002–2024) UT 14 (2016–2025) CA 10 (1989–2015) ND 8 (1993–2016) NC 8 (1982–2022) OH 8 (1981–2018) MI 7 (1990–2023) IL 7 (1984–2000) ME 7 (1992–2021) DE 6 (1984–2025) LA 6 (1994–2007) KS 5 (1988–2020) WA 5 (1984–2004) NY 5 (1981–2009) AZ 4 (1982–2018) CO 4 (2013–2022) IN 4 (1994–2020) OR 3 (1982–1985) WI 3 (1986–2001) HI 3 (2008–2010) WY 3 (2002–2004) MO 2 (2014–2016) IA 2 (1982–1999) MT 2 (1982–1982) NJ 2 (2003–2023) OK 2 (2003–2003) NH 2 (1988–2007)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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