## Facts

- Congress funded Aid to Families with Dependent Children (AFDC) through statutes that set reimbursement levels for participating jurisdictions.
- Federal provisions capped or reduced AFDC reimbursement to Puerto Rico compared to the fifty states.
- AFDC recipients residing in Puerto Rico filed a class action in the U.S. District Court for the District of Puerto Rico against the Secretary of Health, Education, and Welfare, alleging the funding disparity violated equal protection as applied through the Fifth Amendment.
- The district court held the statutory scheme unconstitutional under the Fifth Amendment’s equal protection component.
- The Secretary sought review in the Supreme Court, which resolved the case in a short per curiam disposition.

## Issues

1. Whether federal statutes providing Puerto Rico a lower level of AFDC reimbursement than the states violate the Fifth Amendment’s equal protection component.
2. Whether Congress may treat Puerto Rico differently from the states in federal benefit programs under the Territory Clause, and if so, under what standard of review.

## Decision

- The Supreme Court reversed the district court.
- The Court held that Congress may treat Puerto Rico differently from the states so long as there is a rational basis for the distinction.
- The Court concluded the differential AFDC reimbursement to Puerto Rico satisfied rational-basis review, relying on the same considerations previously accepted in a similar benefits context.
- Justice Marshall dissented, objecting to summary resolution and arguing the issue warranted full briefing and argument.
- Justices Brennan and Blackmun indicated they would have noted probable jurisdiction and set the case for oral argument because they were not persuaded that the prior summary disposition clearly controlled.

## Legal Principles

- Under the Territory Clause, Congress has broad authority to enact different rules for territories than for states.
- Classifications treating Puerto Rico differently from the states in federal benefits legislation are reviewed under rational-basis scrutiny.
- A rational basis may be supported by factors including: Puerto Rico residents’ different contribution to the federal treasury, the high fiscal cost of extending full state-level benefits, and concerns that increased benefits could disrupt the Puerto Rico economy.

## Conclusion

The Court upheld Congress’s decision to provide Puerto Rico lower AFDC reimbursement than the states, holding that differential treatment of territories is constitutional under the Fifth Amendment’s equal protection component when supported by a rational basis.


Harris v. Rosario, 446 U.S. 651 (1980)