April 21, 2022

Supreme Court Decides United States v. Vaello Madero

On April 21, 2022, the U.S. Supreme Court decided United States v. Vaello Madero, No. 20-303, holding that the Fifth Amendment’s Due Process Clause does not require Congress to make Supplemental Security Income (SSI) benefits available to residents of Puerto Rico to the same extent that it makes those benefits available to residents of the States.

Jose Luis Vaello Madero received SSI as a New York resident. In 2013 he moved to Puerto Rico; and the government, unaware of his move, continued to pay him benefits. Vaello Madero was not eligible for the benefits as a Puerto Rico resident, and the government sued to recover its payments. Vaello Madero argued that he was entitled to the same benefits under the equal-protection component of the Fifth Amendment’s Due Process Clause. The district court sided with Vaello Madero, and the First Circuit affirmed.

In an 8-1 opinion, the Supreme Court reversed. The Court held that Congress can, and often does, legislate differently with respect to the Territories, including Puerto Rico. As a result, residents of Puerto Rico are subject to different federal tax and benefits programs. So, while residents of Puerto Rico pay certain federal taxes, they are exempt from others. Conversely, residents of Puerto Rico may receive certain federal benefits, but are ineligible for others.

The Court explained that this outcome is consistent with its precedent allowing Congress to treat Puerto Rico differently for the purpose of federal benefits so long as there is a rational basis for its actions. Congress has a rational basis for devising a different benefits scheme for Puerto Rico, because of the different tax scheme imposed on Puerto Rico’s residents.

Justice Kavanaugh authored the opinion of the Court. Justices Thomas and Gorsuch filed concurring opinions. Justice Sotomayor filed a dissenting opinion.

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