United States v. Vaello-Madero

The Constitution does not require Congress to make Supplemental Security Income benefits available to the residents of Puerto Rico. Justice Brett Kavanaugh authored the 8-1 majority opinion of the Court reversing the lower court. Two precedents dictate the answer to the question presented in this case. In Califano v. Torres, 435 U.S. 1 (1978), the Court held that Congress’s decision not to extend Supplemental Security Income (SSI) to Puerto Rico did not violate the constitutional right to interstate travel because Congress had a rational basis for that decision (that residents of Puerto Rico were exempt from paying federal taxes). And in Harris v. Rosario, 446 U.S. 651 (1980), the Court held that Congress’s differential treatment of Puerto Rico did not violate the equal protection component of the Fifth Amendment’s Due Process Clause because it had the same rational basis for doing so. Applying these two precedents to the present case, the Court concluded that because Congress had a rational basis for the differential treatment, it was not required to extend SSI benefits to the residents of Puerto Rico. Justice Clarence Thomas authored a concurring opinion to suggest that the Fourteenth Amendment’s Citizenship Clause is a better basis for prohibiting the federal government from discriminating on the basis of race than the so-called equal protection component of the Fifth Amendment’s Due Process Clause. Justice Neil Gorsuch authored a concurring opinion noting that although no party asked the Court to overrule the Insular Cases, in which the Court held that the federal government could rule Puerto Rico and other territories without regard to the Constitution, those cases are based on racial stereotypes and “deserve no place in our law.” Justice Sonia Sotomayor authored a dissenting opinion, arguing that there is no rational basis for treating needy citizens living within a territory of the United States so differently from others.