## Facts

- Congress created the Supplemental Security Income (SSI) program in 1972 as a federally administered benefits scheme for the aged, blind, and disabled.
- The statute limited SSI eligibility to “residents of the United States,” defined as the 50 States and the District of Columbia.
- Several individuals received SSI while living in States and later relocated to Puerto Rico.
- Their SSI benefits were terminated solely because Puerto Rico was excluded from the statutory definition of “United States” for SSI purposes.
- The recipients sued, claiming the exclusion violated the constitutional right to travel by penalizing their move from a State to Puerto Rico.
- A three-judge federal district court agreed and held the limitation unconstitutional as applied to them, reasoning the restriction burdened travel and lacked a compelling justification.
- The Secretary of Health, Education, and Welfare appealed directly to the Supreme Court.

## Issues

1. Whether limiting SSI benefits to residents of the 50 States and the District of Columbia, thereby excluding Puerto Rico, is unconstitutional as applied to individuals who lost SSI after moving from a State to Puerto Rico under a right-to-travel theory.
2. What level of constitutional scrutiny applies to Congress’s geographic classification in a federal social welfare program affecting residents of Puerto Rico.

## Decision

- The Supreme Court reversed in a per curiam decision.
- The Court held the SSI residency restriction was not unconstitutional as applied to persons who lost SSI benefits upon moving to Puerto Rico.
- The Court rejected the claim that the constitutional right to travel requires continued payment of SSI after relocation to Puerto Rico.
- The Court treated the exclusion of Puerto Rico as a permissible congressional choice supported by rational justifications, including Puerto Rico’s distinct tax and fiscal treatment and the costs and potential disruption of extending SSI.

## Legal Principles

- The constitutional right to travel does not require the federal government to continue paying a benefits program limited by statute to the States and the District of Columbia when a recipient moves to Puerto Rico.
- Federal social welfare classifications are generally upheld if they are rational and not invidiously discriminatory; strict scrutiny is not triggered merely because a benefits change follows a move to a territory.
- Congress may treat Puerto Rico differently from the States in federal benefits legislation when the distinction is supported by legitimate fiscal and structural considerations tied to Puerto Rico’s status.

## Conclusion

The Court upheld Congress’s decision to exclude Puerto Rico from SSI and ruled that individuals who move from a State to Puerto Rico have no constitutional entitlement, under the right to travel, to retain SSI benefits unavailable to other Puerto Rico residents.


Califano v. Torres, 435 U.S. 1 (1978)