United States v. Vaello Madero

United States v. Vaello Madero, 596 U.S. 159 (2022), was a United States Supreme Court case related to the constitutionality of the exclusion of United States citizens residing in Puerto Rico from the Supplemental Security Income program. In an 8–1 decision, the Court ruled that as Congress had been granted broad oversight of United States territories by Article Four of the United States Constitution , the exclusion of the territories by Congress from programs like Supplemental Security Income did not violate the Due Process Clause of the Fifth Amendment .

Contents

• 1 Background

• 2 Supreme Court

  • 2.1 Opinion of the Court

  • 2.2 Concurrences

    • 2.2.1 Justice Thomas's concurrence

      • 2.2.1.1 Section I

      • 2.2.1.2 Section II

    • 2.2.2 Justice Gorsuch's concurrence

  • 2.3 Dissent

• 3 See also

• 4 References

• 5 External links

Background

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The Supplemental Security Income (SSI) program is a benefit for older or disabled citizens who are unable to care for themselves. As established by act of Congress, the benefits are available to all citizens of the 50 states, the District of Columbia, and the Northern Mariana Islands , but do not cover residents of the other United States territories , including Puerto Rico .

Jose Luis Vaello Madero was a recipient of SSI benefits while living in New York, and then moved to Puerto Rico in 2013. He continued to receive SSI benefits, but eventually the government discovered his new residence, terminated the SSI benefits and sought to recover approximately $28,000 he had improperly received while in Puerto Rico. A federal district judge and the United States Court of Appeals for the First Circuit found that this exclusion violated the equal protection principle of the Fifth Amendment to the United States Constitution 's due process clause, which was first established in _Bolling v. Sharpe _.

Supreme Court

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Certiorari was granted in the case on March 1, 2021. The argument in this case was held on November 9, 2021, and the decision was announced on April 21, 2022. Associate Justice Brett Kavanaugh delivered the opinion of the court. Associate Justices Clarence Thomas and Neil Gorsuch wrote concurrences. Associate Justice Sonia Sotomayor wrote a dissenting opinion.

Opinion of the Court

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Justice Kavanaugh's opinion represented the views of eight justices; all sitting justices except Justice Sotomayor. The Court held that the "equal-protection component" of the Fifth Amendment 's Due Process Clause did not require Congress to allow Puerto Rico residents to receive Supplemental Security Income benefits. The Court gave several reasons for this ruling. First, Congress has broad authority under the Territory Clause of Article IV, Section 3 to "make all needful Rules and Regulations respecting the Territory ... belonging to the United States". The Court noted that residents of Puerto Rico are not required by Congress to pay certain federal taxes, and in return do not get some federal benefits. Second, the Court noted that the statute authorizing the Supplemental Security Income program specifically defined the United States as "the 50 states and the District of Columbia". Third, the Court noted its prior decisions of _Califano v. Torres _ (1978), which found Congress's exclusion of Puerto Rico from SSI did not violate the right to interstate travel, and _Harris v. Rosario _ (1980), which found that Congress can "treat Puerto Rico differently from States so long as there is a rational basis for its actions" and that Puerto Rico's different tax burden was a rational basis to exclude Puerto Rico from a different benefit program. The Court found these precedents "dictate the result here". The Court concluded by saying that Congress could include Puerto Rico in the SSI program, but it was not required to do so.

Concurrences

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Both Justice Thomas and Justice Gorsuch joined the opinion of the Court in full. Justice Thomas wrote separately to question whether the Fifth Amendment contains an "equal-protection component" and to suggest that the Fourteenth Amendment 's Citizenship Clause may be the text of the Constitution that prohibits racial discrimination by the federal government. Justice Gorsuch wrote separately to call for the overruling of the Insular Cases , which stated that Puerto Rico and other unincorporated Territories could be ruled by the federal government "largely without regard to the Constitution".

Justice Thomas's concurrence

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Justice Thomas noted that he previously has joined and written opinions applying the "doctrine" that the Fifth Amendment's Due Process Clause has an "equal protection component" that is similar to the Fourteenth Amendment's Equal Protection Clause. However, he "now doubt[s] whether it comports with the original meaning of the Constitution".

Section I

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In Section I, Justice Thomas discusses how the Supreme Court has previously interpreted the Fifth Amendment's Due Process Clause and lists his criticisms of the logic behind _Bolling v. Sharpe _ (1954). Thomas claims that Bolling "read an equal protection principle into the Fifth Amendment". He then criticizes the logic of Bolling as similar to _Lochner v. New York _ (1905), and reiterates his long-standing opposition to substantive due process . He also critiques Bolling for interpreting "liberty" in the Fifth Amendment's Due Process Clause to include [positive rights](https://en.wikipedia.org/wiki/Positive_rights "Pos

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