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United States v. Vaello-Madero

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Supreme Court of the United States
United States v. Vaello-Madero
Term: 2021
Important Dates
Argued: November 9, 2021
Decided: April 21, 2022
Outcome
reversed
Vote
8-1
Majority
Brett Kavanaugh • Chief Justice John G. Roberts • Clarence Thomas • Stephen Breyer • Samuel Alito • Elena Kagan • Neil Gorsuch • Amy Coney Barrett
Concurring
Clarence Thomas • Neil Gorsuch
Dissenting
Sonia Sotomayor

United States v. Vaello-Madero is a case that was decided by the Supreme Court of the United States on April 21, 2022, during the court's October 2021-2022 term. The case was argued on November 9, 2021.

The court reversed the decision of the United States Court of Appeals for the 1st Circuit in an 8-1 ruling, holding that the Constitution does not require Congress to extend Supplemental Security Income (SSI) benefits to Puerto Rican residents. Justice Brett Kavanaugh delivered the majority opinion of the court. Justices Clarence Thomas and Neil Gorsuch filed concurring opinions. Justice Sonia Sotomayor filed a dissenting opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: José Luis Vaello-Madero, a Puerto Rican-born United States citizen, was receiving benefit payments under the Supplemental Security Income (SSI) provisions of the Social Security Act while living in New York. Once Vaello-Madero returned to Puerto Rico, the Social Security Administration (SSA) discontinued his benefits based on a statutory requirement that an SSI beneficiary live within the 50 U.S. states, the District of Columbia, or the Northern Mariana Islands.[2]


    The United States filed suit in the United States District Court for the District of Puerto Rico for repayment of benefits Vaello-Madero received after moving from New York to Puerto Rico; Vaello-Madero countersued that the SSI statute violated his right to equal protection under the Fifth Amendment. The district court found for Vaello-Madero, holding that Congress had no rational basis for discriminating against U.S. citizens resident in Puerto Rico in passing the SSI provisions. On appeal, the United States Court of Appeals for the First Circuit affirmed.[2] Click here to learn more about the case's background.

  • The issue: The case concerned the equal protection component of the Fifth Amendment's due process clause as it applies to residents of Puerto Rico being denied benefits under the Supplemental Security Income (SSI) program of the Social Security Act.
  • The questions presented: "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."[3]
  • The outcome: The court reversed the 1st Circuit's decision in an 8-1 ruling, holding that the Constitution does not require Congress to extend Supplemental Security Income (SSI) benefits to Puerto Rican residents.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 1st Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    In 1985, José Luis Vaello-Madero, a Puerto Rican-born United States citizen, moved to New York from Puerto Rico. During his residence in New York, he experienced severe health problems and in June 2012 was deemed eligible for and began receiving payments under the Supplemental Security Income (SSI) provisions of the Social Security Act.[2] His SSI payments were made monthly by direct deposit into his account with a New York bank.

    In 2013, Vaello-Madero moved back to Puerto Rico to care for his ill wife. He became aware of issues with his SSI payments related to his move to Puerto Rico in 2016 after filing for Title II Social Security benefits at the Social Security Administration (SSA) office in Puerto Rico. He received notice that his SSI benefits would be discontinued due to his residing outside the United States for more than 30 consecutive days.[2] The SSA made the determination based on statutory provisions that require an SSI beneficiary to be a "resident of the United States," which, "when used in a geographical sense, means the 50 States and the District of Columbia."[4] In 1976, the Northern Mariana Islands were added as a geographic location within the scope of SSI benefits pursuant to Public Law 94-241.[2]

    The United States subsequently filed suit against Vaello-Madero in the United States District Court for the District of Puerto Rico seeking repayment of $28,081 in SSI benefits that the United States alleged was improperly paid to Vaello-Madero between 2013—the time he left New York—and 2016—the time the SSA discontinued his SSI benefits. Vaello-Madero countersued claiming that "the exclusion of Puerto Rico residents from the SSI program violated the equal protection guarantees of the Fifth Amendment."[2]

    The district court found for Vaello-Madero, holding that the two U.S. Supreme Court cases that the United States relied on to justify the differential treatment by Congress of Puerto Rican residents—Califano v. Gautier Torres and Harris v. Rosario—were distinct from the present case. The district court further held that when a rational basis review standard was applied to the Supplemental Security Income (SSI) provisions of the Social Security Act, "[T]he discriminatory statute at bar fails to pass rational basis constitutional muster. United States citizens residing in Puerto Rico are deprived of receiving SSI benefits based solely on the fact that they live in a United States territory. Classifying a group of the Nation's poor and medically neediest United States citizens as 'second tier' simply because they reside in Puerto Rico is by no means rational."[5]

    On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision, holding that neither of the Supreme Court's rulings in Califano v. Gautier Torres or Harris v. Rosario applied to the present case and that the SSI statute failed to pass a rational basis review.[2]

    Questions presented

    The petitioner presented the following questions to the court:[3]

    Questions presented:
    “ 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.[6] ”

    Oral argument

    The case was argued before the U.S. Supreme Court on November 9, 2021.

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In an 8-1 opinion, the court reversed the judgment of the United States Court of Appeals for the 1st Circuit, holding that the Constitution does not require Congress to extend Supplemental Security Income (SSI) benefits to Puerto Rican residents. Justice Brett Kavanaugh wrote the majority opinion. Justices Clarence Thomas and Neil Gorsuch filed concurring opinions. Justice Sonia Sotomayor filed a dissenting opinion.[1]

    Opinion

    In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]

    “

    The United States includes five Territories: American Samoa, Guam, the Northern Mariana Islands, the U. S. Virgin Islands, and Puerto Rico. This case involves Puerto Rico, which became a U. S. Territory in 1898 in the wake of the Spanish-American War.

    For various historical and policy reasons, including local autonomy, Congress has not required residents of Puerto Rico to pay most federal income, gift, estate, and excise taxes. Congress has likewise not extended certain federal benefits programs to residents of Puerto Rico.

    The question presented is 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 Congress makes those benefits available to residents of the States. In light of the text of the Constitution, longstanding historical practice, and this Court’s precedents, the answer is no.
    ...
    The Constitution affords Congress substantial discretion over how to structure federal tax and benefits programs for residents of the Territories. Exercising that discretion, Congress may extend Supplemental Security Income benefits to residents of Puerto Rico. Indeed, the Solicitor General has informed the Court that the President supports such legislation as a matter of policy. But the limited question before this Court is whether, under the Constitution, Congress must extend Supplemental Security Income to residents of Puerto Rico to the same extent as to residents of the States. The answer is no. We therefore reverse the judgment of the U. S. Court of Appeals for the First Circuit. [6]

    		”
    —Justice Brett Kavanaugh

    Concurring opinion

    Justice Thomas

    Justice Clarence Thomas filed a concurring opinion.

    In his concurring opinion, Justice Thomas wrote:[1]

    “

    I join the opinion of the Court. I write separately to address the premise that the Due Process Clause of the Fifth Amendment contains an equal protection component whose substance is “precisely the same” as the Equal Protection Clause of the Fourteenth Amendment. Weinberger v. Wiesenfeld, 420 U. S. 636, 638, n. 2 (1975). Although I have joined the Court in applying this doctrine, see Adarand Constructors, Inc. v. Peña, 515 U. S. 200, 213–217 (1995), I now doubt whether it comports with the original meaning of the Constitution. Firmer ground for prohibiting the Federal Government from discriminating on the basis of race, at least with respect to civil rights, may well be found in the Fourteenth Amendment’s Citizenship Clause. [6]

    		”
    —Justice Clarence Thomas

    Justice Gorsuch

    Justice Neil Gorsuch filed a concurring opinion.

    In his concurring opinion, Justice Gorsuch wrote:[1]

    “

    A century ago in the Insular Cases, this Court held that the federal government could rule Puerto Rico and other Territories largely without regard to the Constitution. It is past time to acknowledge the gravity of this error and admit what we know to be true: The Insular Cases have no foundation in the Constitution and rest instead on racial stereotypes. They deserve no place in our law.
    ...
    The case before us only defers a long overdue reckoning. Rather than ask the Court to overrule the Insular Cases, both sides in this litigation work from the shared premise that the equal protection guarantee under which Mr. Vaello Madero brings his claim is a “fundamental” feature of the Constitution and thus applies in “unincorporated” Territories like Puerto Rico. See Tr. of Oral Arg. 10–11; Brief for United States 12. Proceeding on the parties’ shared premise, the Court applies the Constitution and holds that the conduct challenged here does not offend its terms. All that may obviate the necessity of overruling the Insular Cases today. But it should not obscure what we know to be true about their errors, and in an appropriate case I hope the Court will soon recognize that the Constitution’s application should never turn on a governmental concession or the misguided framework of the Insular Cases. Asked why he dissented in those cases year after year, Justice Harlan replied that “‘no question can be settled until settled right.’” Coudert 842. We should settle this question right.
    ...
    Because no party asks us to overrule the Insular Cases to resolve today’s dispute, I join the Court’s opinion. But the time has come to recognize that the Insular Cases rest on a rotten foundation. And I hope the day comes soon when the Court squarely overrules them. We should follow Justice Harlan and settle this question right. Our fellow Americans in Puerto Rico deserve no less. [6]

    		”
    —Justice Neil Gorsuch

    Dissenting opinion

    Justice Sonia Sotomayor filed a dissenting opinion.

    In his/her/their dissent, Justice Sotomayor wrote:[1]

    “

    The Supplemental Security Income (SSI) program provides a guaranteed minimum income to certain vulnerable citizens who lack the means to support themselves. If they meet uniform federal eligibility criteria, recipients are entitled to SSI regardless of their contributions, or their State’s contributions, to the United States Treasury, which funds the program. Despite these broad eligibility criteria, today the Court holds that Congress’ decision to exclude citizen residents of Puerto Rico from this important safety-net program is consistent with the Fifth Amendment’s equal protection guarantee. I disagree. In my view, there is no rational basis for Congress to treat needy citizens living anywhere in the United States so differently from others. To hold otherwise, as the Court does, is irrational and antithetical to the very nature of the SSI program and the equal protection of citizens guaranteed by the Constitution. I respectfully dissent. [6]

    		”
    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]

    The court agreed to hear 68 cases during its 2021-2022 term.[10] Four cases were dismissed and one case was removed from the argument calendar.[11]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, United States v. Vaello Madero, decided April 21, 2022
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 United States Court of Appeals for the 1st Circuit, United States v. Vaello-Madero, decided April 10, 2020
    3. ↑ 3.0 3.1 U.S. Supreme Court, "No. 20-303: Questions Presented," accessed March 1, 2021
    4. ↑ United States Code, "42 U.S.C. § 1382c - Definitions," accessed March 1, 2021
    5. ↑ United States District Court for the District of Puerto Rico, United States v. Vaello-Madero, decided February 4, 2019
    6. ↑ 6.0 6.1 6.2 6.3 6.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 9, 2021
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 9, 2021
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    10. ↑ Consolidated cases are counted as one case for purposes of this number.
    11. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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