Facts
- Federal law governing Medicare Part B limited enrollment for aliens age 65+ unless they (1) were admitted for permanent residence and (2) had resided in the United States for at least five years.
- Guillermo Diaz and Manuela Clara, elderly lawful resident aliens, applied for Part B and were denied because they did not satisfy the statute’s alien-eligibility requirements.
- Miguel Espinosa was a lawful permanent resident but did not apply initially because he could not satisfy the five-year residence condition; after litigation began, he filed an application.
- The Secretary of Health, Education, and Welfare argued dismissal for failure to exhaust administrative remedies, but conceded there were no disputed factual issues and that the applications would be denied under the statute.
- A three-judge federal district court certified a class, rejected the exhaustion argument, held the five-year condition unconstitutional under the Fifth Amendment, treated the alien-eligibility provisions as unenforceable, and granted declaratory and injunctive relief.
Issues
- Whether the district court had jurisdiction under 42 U.S.C. § 405(g) despite incomplete administrative exhaustion.
- Whether Congress may, consistent with the Fifth Amendment’s Due Process Clause, condition Medicare Part B eligibility for aliens on lawful permanent resident status and five years’ U.S. residence.
Decision
- The Supreme Court reversed.
- The Court held jurisdiction existed at least as to Espinosa because the nonwaivable presentment requirement was satisfied by his application, and the Secretary’s concessions functioned as a waiver of further exhaustion and as a final denial for § 405(g) purposes.
- The Court upheld 42 U.S.C. § 1395o(2)(B), concluding that limiting Part B eligibility to lawful permanent residents with at least five years’ residence did not violate the Fifth Amendment.
Legal Principles
- Under 42 U.S.C. § 405(g), presentment of a claim to the agency is a nonwaivable jurisdictional condition; other exhaustion elements may be waived where the agency effectively treats the claim as finally denied.
- The Fifth Amendment protects aliens as “persons,” but that protection does not require that all aliens receive the same benefits as citizens.
- Equal-protection-type limits apply to the federal government through the Fifth Amendment, but federal classifications involving aliens—especially in areas tied to immigration and naturalization—receive substantial judicial deference.
- Congress may draw distinctions between citizens and aliens, and among classes of aliens, in federal benefits programs so long as the lines drawn are not wholly irrational.
- Lawful permanent resident status and a durational residence condition may be used as rational proxies for a durable connection to the United States in allocating access to federal benefits.
Conclusion
The Court sustained federal authority to restrict Medicare Part B enrollment for noncitizens to those who are lawful permanent residents with at least five years’ U.S. residence, and it recognized jurisdiction despite incomplete exhaustion where presentment occurred and the agency effectively rendered a final denial.