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United States v. Vaello-Madero

1st Circuit Court, No. 19-1390, 141 S. Ct. 1462 (2021)
U.S. Supreme Court, 956 F. 3d 12, reversed – April 21, 2022

Keywords: Equal Protection Clause, Supplemental Security Income (SSI), Fifth Amendment, disability benefits, First Circuit, Puerto Rico

Summary and Facts of the Case

The United States of America sued Jose Luis Vaello-Madero, who was receiving Supplemental Security Income (“SSI”) Disability Benefits. The government sued to collect money for benefits paid to Mr. Vaello-Madero after he moved from New York to Puerto Rico. The SSI program started in 1972 for people living in the 50 states, the District of Columbia, and people living in the Northern Mariana Islands. The program did not include Puerto Rico. Because he moved to Puerto Rico in 2013, the government said he could  no longer get SSI benefits.  Vaello-Madero said  denying him SSI benefits because he moved to Puerto Rico violated the Equal Protection Clause of the Fifth Amendment of the U.S. Constitution. Both sides asked for summary judgment (a court decision made without a full trial) on the Constitutional claim. The District Court for the District of Puerto Rico allowed Vaello-Madero’s motion. The United States appealed.

The First Circuit Court of Appeals agreed with the district court decision.

Issue of the Case

Is excluding Puerto Rico residents from getting SSI benefits a violation of the Fifth Amendment of the U.S. Constitution?

Arguments and Analysis

Mr. Vaello-Madero said that the U.S. Government discriminated against residents of Puerto Rico who were qualified to receive SSI benefits. Vaello-Madero claimed that being denied benefits was not related to a legitimate government interest, meaning government created SSI as a national program to provide monthly payments to people aged 65 and up, or who are blind or disabled.

Vaello-Madero claimed that excluding residents of Puerto Rico is against the stated purpose of the program to provide SSI payments to the nation’s elderly, disabled, or blind.

The Government relied on two cases to show why it believed its position was correct.

The first case was Califano v. Gautier Torres. This case decided that denial of SSI benefits to a recipient from Connecticut who moved to Puerto Rico, was not a violation of the recipient’s right to travel. Califano is different than United States v. Vaello-Madero as Vaello-Madero is about equal protection under the Fifth Amendment of the Constitution.

The second case is Harris v. Rosario, a lawsuit about the Aid to Families with Dependent Children (AFDC) program. In this case, citizens of Puerto Rico received less money than persons living in the States. However, this case did not look at SSI benefits, so the court refused the argument.

The Government also said that Puerto Ricans did not pay federal taxes preventing SSI benefits to Puerto Ricans. However, this court found that Puerto Rico does make large contributions to the US federal treasury, often paying more than taxpayers in at least six states in the United States. Due to this, the court rejected the Government’s argument that Puerto Rico residents cannot get SSI benefits because they do not contribute to the federal treasury Further, this court said that deciding who gets SSI benefits based on contributions to the federal treasury was is not the purpose of SSI which is to help people who struggle to pay into the federal treasury to begin with.

Finally, the government claimed that excluding Puerto Rico residents from getting SSI benefits was government in the government’s interests because paying benefits to SSI recipients is expensive.. However, the court rejected this argument too, claiming that cost alone is not something to consider. Additionally, the Government argued that under Palmore v. United States, “Congress may legislate differently for the territories than for the states, and differently for one territory than for another.” The court refused this argument too, because the government failed to show enough proof that Fifth Amendment guarantees should be put aside.

Rulings

The 1st Circuit Court of Appeals ruled that excluding Puerto Rico residents, like Mr. Vaello-Madero, from getting SSI benefits violates the Equal Protection Clause of the Fifth Amendment.

On April 21, 2022, in an 8-1 ruling, the Supreme Court reversed the lower court and ruled that the Constitution does not require Congress to extend Supplemental Security Income benefits to residents of Puerto Rico.

Policy and Practice

When deciding if a law the government passes is constitutional government under the Fifth Amendment, courts must look at the government’s reason for enacting the law and whether a particular group will be unfairly impacted by the legislation. To be considered constitutional, under rational basis review, the government law must be rationally related to a legitimate government interest.

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