Supreme Court of the United States · 2022 · Constitutional Law
Constitutional LawEqual ProtectionTerritoriesPuerto RicoSupplemental Security IncomeFifth Amendmentequal protectionDue Process Clause
Facts
Congress has long structured federal taxes and benefits for Puerto Rico differently from those for the States. Residents of Puerto Rico generally are exempt from most federal income, gift, estate, and excise taxes, though they generally pay Social Security, Medicare, and unemployment taxes and are eligible for some federal benefits programs. SSI, however, is available to residents of the 50 States and the District of Columbia, but not Puerto Rico; instead, Puerto Rico residents receive assistance through a different program funded in part by the federal government and in part by Puerto Rico. Vaello Madero received SSI while living in New York, moved to Puerto Rico in 2013, continued receiving benefits after the government failed to detect the move, and the government later sought restitution of more than $28,000 in overpayments.
Issue
Whether the equal-protection component of the Fifth Amendment's Due Process Clause requires Congress to make Supplemental Security Income benefits available to residents of Puerto Rico to the same extent that it makes those benefits available to residents of the States.
Rule
When a federal law treats differently groups that are not defined by a suspect classification and do not implicate a fundamental right, the classification satisfies equal protection if there is a rational basis for it. In legislating for the Territories under the Territory Clause, Congress may treat Puerto Rico differently from the States, and Puerto Rico's unique tax status provides a rational basis for excluding its residents from SSI.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Congress creates a federal cash-assistance program for elderly people with very limited means. The statute makes residents of the 50 States and the District of Columbia eligible, but excludes residents of Puerto Rico, where Congress has long maintained a different mix of federal taxes and benefits and where residents generally do not pay most federal income, gift, estate, and excise taxes. Elena Cruz, a U.S. citizen living in San Juan, sues in federal court under the Fifth Amendment.
What is the strongest argument that the statute is constitutional?
Explanation. The majority assumed equal protection applies, but held that when a federal law treats differently groups that are not defined by a suspect classification and do not implicate a fundamental right, rational-basis review applies. In legislating for Territories, Congress has broad authority under the Territory Clause, and Puerto Rico's distinct tax status provides a rational basis for different treatment. The government need not satisfy strict scrutiny, Puerto Rico residents are not outside constitutional protection, and the majority did not say they pay no federal taxes whatsoever.