The federal government is permitted to treat U.S. citizens differently depending upon whether they reside in an actual state or a territorial possession of the United States.
That was the conclusion reached by the Supreme Court in an 8-1 decision released on Thursday with regard to a man from Puerto Rico denied eligibility for a federal anti-poverty benefits program, the Conservative Brief reported.
More to the point, the court found that it did not violate the U.S. Constitution for Congress to set different standards of eligibility in terms of certain federal benefits programs for citizens that resided in the 50 states plus the District of Columbia versus those who resided in the several territories possessed by the U.S.
Eligibility for benefits dependent upon the place of residence
At issue in this case, according to Reuters, was a Puerto Rican man named Jose Luis Vaello Madero who, while living in New York, applied for and received Supplemental Security Income (SSI) benefits, a federal aid program for the elderly and disabled that, by statute is only applicable for residents of the 50 states and D.C.
When Vaello Madero moved back to Puerto Rico he continued to receive the monthly benefit for a time until the government realized where he was residing, ceased all future payments, and sought to recoup approximately $28,000 in payments that he had received while ineligible.
The man then sued on the claim that his constitutional due process and equal protection rights as a U.S. citizen had been violated and both a district court and appeals court ruled in his favor, prompting the government to appeal the matter to the Supreme Court.
Up to Congress to determine the tax burden and benefits eligibility
SCOTUSblog reported that the Supreme Court, in a surprising 8-1 ruling, overturned those favorable decisions by the lower courts in the case of United States v. Vaello Madero and determined that residents of Puerto Rico and other territories don’t have a constitutional right to receive all of the same benefits that residents of the 50 states and D.C. are entitled to receive.
Justice Brett Kavanaugh wrote the majority opinion and held that the Constitution does not explicitly require Congress to extend the same set of benefits to territories as it does to states, and cited two prior high court rulings, Califano v. Torres in 1978 and Harris v. Rosario in 1980, as providing precedent on the matter.
The argument essentially boiled down to the fact that since residents of certain territories like Puerto Rico were exempted by Congress from paying certain taxes, so too could Congress exempt those same residents from being eligible for certain benefits under the “deferential rational-basis” test of scrutiny.
“The Constitution affords Congress substantial discretion over how to structure federal tax and benefits programs for residents of the Territories,” Kavanaugh concluded, and while Congress “may” decide to extend certain benefits to territorial residents, there is nothing in the Constitution that says Congress “must” extend those particular benefits.
Dissent from Sotomayor, concurrence with concerns from Thomas and Gorsuch
SCOTUSblog noted that Justice Sonia Sotomayor authored a dissenting opinion in which she deemed the majority ruling to be “irrational and antithetical” to the nature of the SSI program in question — which is intended to aid those who are in poverty who don’t pay taxes anyway — as well as the guarantee of equal protection in the Constitution.
Justices Clarence Thomas and Neil Gorsuch also wrote their own opinions separately in which they concurred with the majority decision but expressed disagreement with the underlying premise and precedents as well as their hope that Congress, or the court itself in an “appropriate” future case, might rectify the disparate treatment of U.S. citizens dependent solely upon whether they reside in a state or territory.
