## Facts

- Congress created Supplemental Security Income (SSI) to provide cash assistance to certain low-income individuals who are aged, blind, or disabled.
- By statute, SSI is available to residents of the 50 states, the District of Columbia, and the Northern Mariana Islands, but not to residents of Puerto Rico.
- José Luis Vaello Madero, a U.S. citizen born in Puerto Rico, lived in New York and began receiving SSI benefits in 2012.
- In 2013, he moved to Puerto Rico; the Social Security Administration continued paying SSI for several years.
- After discovering the move, the government terminated benefits and sued to recover more than $28,000 in payments made while he resided in Puerto Rico.
- Vaello Madero argued that excluding Puerto Rico residents from SSI violates the equal-protection component of the Fifth Amendment’s Due Process Clause.
- The district court and the First Circuit agreed with Vaello Madero and held the exclusion unconstitutional.

## Issues

1. Whether the equal-protection component of the Fifth Amendment’s Due Process Clause requires Congress to extend SSI benefits to residents of Puerto Rico on the same terms as residents of the states.

## Decision

- The Supreme Court reversed, 8–1 (Justice Kavanaugh for the Court).
- The Court held the Constitution does not require Congress to extend SSI benefits to residents of Puerto Rico.
- The Court applied rational-basis review, relying on precedent upholding differential treatment of Puerto Rico in federal benefits programs.
- The Court concluded Congress had rational bases for excluding Puerto Rico, including Puerto Rico residents’ different federal tax status and fiscal considerations.
- Justice Sotomayor dissented, concluding the exclusion fails even rational-basis review.

## Legal Principles

- Congress has broad authority under the Territory Clause to legislate for U.S. territories, including creating distinctions between territories and states in federal benefits programs.
- Equal-protection challenges to differential territorial treatment in federal benefits programs are generally evaluated under rational-basis review unless a heightened-scrutiny trigger applies.
- Under rational-basis review, a statute is presumed constitutional and will be upheld if any reasonably conceivable facts provide a rational relation to a legitimate governmental interest.
- Congress may rationally consider territorial tax status and fiscal or administrative consequences when structuring federal tax-and-benefits schemes that treat Puerto Rico differently from states.
- The judgment did not depend on the Insular Cases; the Court resolved the case on the Territory Clause and prior rational-basis precedents concerning Puerto Rico.

## Conclusion

The Court held that excluding Puerto Rico residents from SSI does not violate the Fifth Amendment’s equal-protection component because Congress may distinguish between states and territories in benefits programs when a rational basis supports the classification.


United States v. Vaello Madero, 596 U.S. 159 (2022)