Date Created:
Place Created: Washington, D.C.
Year Created: 2022
Historical Theme:
Description: In 2022, the Supreme Court addressed whether Congress's exclusion of Puerto Rico residents from the Supplemental Security Income (SSI) program violated the Fifth Amendment. In an 8-1 decision in United States v. Vaello Madero, the Court held that it did not. The majority opinion reasoned that Congress has the authority to treat territories differently from states, citing the Territory Clause of the Constitution. The Court found a rational basis for the exclusion in the fact that residents of Puerto Rico are generally exempt from most federal taxes, distinguishing them from residents of states. This ruling affirmed Congress's power to create different legislative frameworks for territories as long as a rational justification exists.
Categories of Documents:
Syllabus
SUPREME COURT OF THE UNITED STATES
Syllabus
UNITED STATES v. VAELLO MADERO
certiorari to the united states court of appeals for the first circuit
No. 20–303. Argued November 9, 2021—Decided April 21, 2022
The Territory Clause of the United States Constitution—which states that Congress may “make all needful Rules and Regulations respecting the Territory . . . belonging to the United States,” Art. IV, §3, cl. 2—affords Congress broad authority to legislate with respect to the U. S. Territories. In exercising that authority, Congress has long maintained different federal tax and benefits programs for residents of the Territories than for residents of the 50 States. For example, residents of Puerto Rico are typically exempt from most federal income, gift, estate, and excise taxes. See 48 U. S. C. §734; see, e.g., 26 U. S. C. §§933, 2209, 4081–4084. But just as not every federal tax extends to residents of Puerto Rico, so too not every federal benefits program extends to residents of Puerto Rico. One such benefits program is Supplemental Security Income (SSI), which by statute applies only to residents of the 50 States and the District of Columbia. 42 U. S. C. §1382c(a)(1)(B)(i). The question presented is whether the equal-protection component of the Fifth Amendment’s Due Process Clause requires Congress to make Supplemental Security Income benefits available to residents of Puerto Rico to the same extent that Congress makes those benefits available to residents of the States.
Here, respondent Jose Luis Vaello Madero received SSI benefits while he was a resident of New York. He then moved to Puerto Rico, where he was no longer eligible to receive those benefits. Unaware of Vaello Madero’s new residence, the Government continued to pay him SSI benefits. The Government eventually sued Vaello Madero to recover those errant payments, which totaled more than $28,000. In response, Vaello Madero invoked the Constitution, arguing that Congress’s exclusion of residents of Puerto Rico from the SSI program violated the equal-protection component of the Fifth Amendment’s Due Process Clause. The District Court and the Court of Appeals agreed.
Held: The Constitution does not require Congress to extend SSI benefits to residents of Puerto Rico. In Califano v. Torres, 435 U.S. 1, and Harris v. Rosario, 446 U.S. 651, the Court applied the deferential rational-basis test to uphold Congress’s decision not to extend certain federal benefits to Puerto Rico, noting that because Congress chose to treat residents of Puerto Rico differently from residents of the States for purposes of tax laws, it could do the same for benefits programs. Those two precedents dictate the result here. Congress’s decision to exempt Puerto Rico’s residents from most federal income, gift, estate, and excise taxes supplies a rational basis for likewise distinguishing residents of Puerto Rico from residents of the States for purposes of the SSI benefits program. Vaello Madero’s contrary position would usher in potentially far-reaching consequences, with serious implications for the Puerto Rican people and the Puerto Rican economy. The Constitution does not require that extreme outcome. Pp. 4–6.
956 F.3d 12, reversed.
Kavanaugh, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Breyer, Alito, Kagan, Gorsuch, and Barrett, JJ., joined. Thomas, J., and Gorsuch, J., filed concurring opinions. Sotomayor, J., filed a dissenting opinion.
Washington, D.C.