United States v. Vaello-Madero, Jose L.

Whether Congress violated the equal-protection component of the Due Process Clause of the Fifth Amendment by establishing Supplemental Security Income—a program that provides benefits to needy aged, blind, and disabled individuals—in the 50 States and the District of Columbia, and in the Northern Mariana Islands pursuant to a negotiated covenant, but not extending it to Puerto Rico.

Supplemental Security Income (“SSI”) is a program of economic assistance for the aged and disabled in all 50 states, but not Puerto Rico. The Social Security Administration sought back-payments for Respondent’s SSI benefits when it learned that he relocated to Puerto Rico. Respondent opposed this action on the grounds that the Puerto Rico exclusion was unconstitutional. The District Court granted summary judgement in favor of Respondent, concluding that the Puerto Rico exclusion violated Due Process because it lacked a rational basis; and the First Circuit affirmed. Petitioner argues that the lower courts’ judgement was incorrect because U.S. territories may be treated differently without violating Due Process if a rational basis justifies it. See Harris v. Rosario, 446 U.S. 651 (1980). Here, Petitioner identified the absence of the federal income tax in Puerto Rico as the rational basis for the Puerto Rico exclusion. Because the federal government has a legitimate interest in restricting its fiscal spending, excluding U.S. territories with no federal income taxes from SSI benefits furthers this interest.