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Mathews v. Diaz

Supreme Court of the United States · 1976 · Constitutional Law

Constitutional LawDue ProcessFederal power over immigration and naturalizationAlienage classificationsFifth Amendmentdue processaliensMedicare Part B

Facts

The appellees were resident aliens over age 65 who sought access to the Medicare Part B supplemental medical insurance program. Diaz and Clara were Cuban refugees who had not been admitted for permanent residence and had lived in the United States less than five years; Espinosa had been admitted for permanent residence but had not resided in the country for the required five years. Section 1395o(2)(B) granted eligibility to citizens age 65 or older who resided in the United States, but required aliens to be lawfully admitted for permanent residence and to have resided continuously in the United States during the five years immediately preceding application. The Secretary denied Diaz and Clara, and the Court treated Espinosa's claim as properly before it based on his filed application and the Secretary's stipulation that the only issue was the statute's constitutionality.

Issue

May Congress constitutionally condition an alien's eligibility for participation in the federal Medicare Part B program on both lawful admission for permanent residence and five years of continuous residence in the United States? Also, did the District Court have jurisdiction to decide Espinosa's claim despite the lack of a formal final administrative denial?

Rule

Under the Fifth Amendment, Congress has broad authority over immigration and naturalization and may draw distinctions between citizens and different classes of aliens in distributing federal welfare benefits. A federal statutory classification governing alien eligibility is constitutional if it is not wholly irrational; it is reasonable for Congress to make an alien's eligibility depend on both the character and the duration of residence. For jurisdiction under 42 U.S.C. § 405(g), the Secretary may waive exhaustion, and a stipulation showing no factual dispute and submission of the constitutional issue on the merits may be treated as tantamount to a final decision.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress creates a federally funded prescription subsidy for residents over age 70. The statute lets citizens enroll if they reside in the United States, but lets aliens enroll only if they are lawful permanent residents who have lived continuously in the United States for three years. Lina Petrov, a lawful permanent resident in Chicago for 18 months, challenges the alien-specific limits under the Fifth Amendment.

How should a court most likely rule?

Explanation. The majority held that, in distributing federal welfare benefits, Congress may distinguish not only between citizens and aliens but also among different classes of aliens. Because regulation of aliens is committed to the political branches, judicial review is narrow, and the classification is upheld if it is not wholly irrational. It is reasonable for Congress to rely on both the character of residence and its duration.