Mathews v. Eldridge test in Alaska

2003Safety, Div. of Motor Vehicles, 20 P.3d 1130, 1135 (Alaska 2001) (using the Mathews v. Eldridge framework to analyze due process challenge to administrative procedure). [19] Mathews, 424 U.S. at 334-35 , 96 S.Ct. 893 . [20] Compare former AMC 3.85.230 with former AMC 3.85.240. [21] DAVIS & PIERCE, ADMINISTRATIVE LAW § 9.4, at 35 (3d ed.1994). [22] Claimants' odds of success would still fluctuate under this rule depending on the number of participating board members. [23] Former AMC 3.85.030(B)-(C). [24] Palmer actually made a similar argument in support of the five-vote requirement in his seco

2003Safety, Div. of Motor Vehicles, 20 P.3d 1130, 1135 (Alaska 2001) (using the Mathews v. Eldridge framework to analyze due process challenge to administrative procedure). [19] Mathews, 424 U.S. at 334-35 , 96 S.Ct. 893 . [20] Compare former AMC 3.85.230 with former AMC 3.85.240. [21] DAVIS & PIERCE, ADMINISTRATIVE LAW § 9.4, at 35 (3d ed.1994). [22] Claimants' odds of success would still fluctuate under this rule depending on the number of participating board members. [23] Former AMC 3.85.030(B)-(C). [24] Palmer actually made a similar argument in support of the five-vote requirement in his seco

2025Servs., Off. of Child.’s Servs., 542 P.3d 1099, 1120 (Alaska 2020) (looking to Mathews v. Eldridge test to evaluate procedural due process argument); see also Patrick, 305 P.3d at 299 - 301 (same). -18- 7741 additional or substitute procedural requirement would entail.[55] Thomason first argues that the hearing she received before the ALJ could not have satisfied due process because the ALJ was not the “actual decision maker[].” She argues that due process demands that she have a hearing before the sanctions committee as the final decisionmaker — but the cases she cites do not support this pro

2024Comm’n, 305 P.3d 292, 299 (Alaska 2013) (“We look to the test set forth by the United States Supreme Court in Mathews v. Eldridge to determine the requirements of due process.”). 98 Mathews v. Eldridge, 424 U.S. 319, 334-35 (1976). -31- 7684 a.

2025We use the Mathews v. Eldridge test to weigh competing considerations when deciding precisely what process is due before the State may deprive a person of a protected liberty or property interest. 25 Under this test we consider: the private interests affected by the official action; 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 fiscal and 23 Nordlund v. State, Department of Corrections, 520 P.3d 1178, 1183-84 (Alaska 2022).

2025We use the Mathews v. Eldridge test to weigh competing considerations when deciding precisely what process is due before the State may deprive a person of a protected liberty or property interest. 25 Under this test we consider: the private interests affected by the official action; 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 fiscal and 23 Nordlund v. State, Department of Corrections, 520 P.3d 1178, 1183-84 (Alaska 2022).

2025We use the Mathews v. Eldridge test to weigh competing considerations when deciding precisely what process is due before the State may deprive a person of a protected liberty or property interest. 25 Under this test we consider: the private interests affected by the official action; 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 fiscal and 23 Nordlund v. State, Department of Corrections, 520 P.3d 1178, 1183-84 (Alaska 2022).

2025We use the Mathews v. Eldridge test to weigh competing considerations when deciding precisely what process is due before the State may deprive a person of a protected liberty or property interest. 25 Under this test we consider: the private interests affected by the official action; 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 fiscal and 23 Nordlund v. State, Department of Corrections, 520 P.3d 1178, 1183-84 (Alaska 2022).

2025We use the Mathews v. Eldridge test to weigh competing considerations when deciding precisely what process is due before the State may deprive a person of a protected liberty or property interest. 25 Under this test we consider: the private interests affected by the official action; 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 fiscal and 23 Nordlund v. State, Department of Corrections, 520 P.3d 1178, 1183-84 (Alaska 2022).

2025We use the Mathews v. Eldridge test to weigh competing considerations when deciding precisely what process is due before the State may deprive a person of a protected liberty or property interest. 25 Under this test we consider: the private interests affected by the official action; 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 fiscal and 23 Nordlund v. State, Department of Corrections, 520 P.3d 1178, 1183-84 (Alaska 2022).

2025Servs., Off. of Child.’s Servs., 542 P.3d 1099, 1120 (Alaska 2020) (looking to Mathews v. Eldridge test to evaluate procedural due process argument); see also Patrick, 305 P.3d at 299 - 301 (same). -18- 7741 additional or substitute procedural requirement would entail.[55] Thomason first argues that the hearing she received before the ALJ could not have satisfied due process because the ALJ was not the “actual decision maker[].” She argues that due process demands that she have a hearing before the sanctions committee as the final decisionmaker — but the cases she cites do not support this pro

2024To evaluate these procedural due process arguments, we use the Mathews v. Eldridge test,97 which requires balancing three factors: 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.[98] Because the Alaska Constitution’

2024To evaluate these procedural due process arguments, we use the Mathews v. Eldridge test, 97 which requires balancing three factors: 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.[98] Because the Alaska Constitution

2024To evaluate these procedural due process arguments, we use the Mathews v. Eldridge test,97 which requires balancing three factors: 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.[98] Because the Alaska Constitution’

2024To evaluate these procedural due process arguments, we use the Mathews v. Eldridge test, 97 which requires balancing three factors: 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.[98] Because the Alaska Constitution

2022In Dennis O., for example, we concluded that “the probable value of appointing counsel was not sufficiently high” because the father “capably represented himself throughout the hearing” and was not able to identify any way the lack of counsel 8 813 P.2d 276 , 283 (Alaska 1991). 9 393 P.3d 401, 406-11 (Alaska 2017) (citing Mathews v. Eldridge, 424 U.S. 319, 335 (1976)). 10 Id. at 408-09 . 11 Id. at 411 . -16- 7610 prejudiced him.12 By contrast, in this case, the superior court observed that the father faced a disadvantage by being incarcerated with limited access to legal materials.

2003Safety, Div. of Motor Vehicles, 20 P.3d 1130, 1135 (Alaska 2001) (using the Mathews v. Eldridge framework to analyze due process challenge to administrative procedure). .

2003Safety, Div. of Motor Vehicles, 20 P.3d 1130, 1135 (Alaska 2001) (using the Mathews v. Eldridge framework to analyze due process challenge to administrative procedure). [19] Mathews, 424 U.S. at 334-35 , 96 S.Ct. 893 . [20] Compare former AMC 3.85.230 with former AMC 3.85.240. [21] DAVIS & PIERCE, ADMINISTRATIVE LAW § 9.4, at 35 (3d ed.1994). [22] Claimants' odds of success would still fluctuate under this rule depending on the number of participating board members. [23] Former AMC 3.85.030(B)-(C). [24] Palmer actually made a similar argument in support of the five-vote requirement in his seco