United States v. Vaello-Madero
United States Court of Appeals for the First Circuit
April 10, 2020, Decided
[*14] TORRUELLA, Circuit Judge. This appeal raises a fundamental question of constitutional law requiring us to consider the equal protection component of the Fifth Amendment as it applies to the residents [**2] of Puerto Rico. Specifically, Appellee claims that the exclusion of Puerto Rico residents from receiving the disability benefits that are granted to persons residing in the fifty States, the District of Columbia, and the Northern Mariana Islands [*15] under the Supplemental Security Income (SSI) provisions of Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1383f, contravenes the equal protection guarantees of the Fifth Amendment. Appellee in this case became eligible and commenced receiving SSI disability benefits while residing in New York. Nevertheless, these benefits were discontinued when the Social Security Administration (SSA) became aware that he had moved to Puerto Rico. The SSA proceeded to enforce the provision of this legislation that requires a recipient of SSI benefits to reside within the United States, defined by statute as the geographical territory of the fifty States, the District of Columbia, and the Northern Mariana Islands, and authorizes the termination of these payments if the recipient resides more than thirty consecutive days outside the "United States" as so defined. See id. §§ 1382c(a)(1)(B)(i), 1382c(e); see also Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States [**3] of America, Pub. L. No. 94-241, § 502(a)(1), 90 Stat. 263, 268 (1976).
A. The factual background of this appeal
] SSI provides benefits to low income individuals who are older than sixty-five, blind, or disabled. See 42 U.S.C. §§ 1382(a), 1382c. In contrast to other types of federal insurance programs, like Social Security Title II benefits, 42 U.S.C. §§ 401-433, which are paid for by payroll taxes, Congress funds SSI from the general treasury. See 42 U.S.C. § 1381; see also Pub. L. No. 116-94, 133 Stat. 2534, 2603 (2019) (funding SSI for fiscal year 2020). SSI is a means-tested program, so only those individuals who meet the age, disability, or blindness requirements and fall beneath the federally mandated income and asset limits are eligible. 42 U.S.C. § 1382.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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956 F.3d 12 *; 2020 U.S. App. LEXIS 11358 **
UNITED STATES OF AMERICA, Plaintiff, Appellant, v. JOSÉ LUIS VAELLO-MADERO, Defendant, Appellee.
Prior History: [**1] APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO. Hon. Gustavo A. Gelpí, U.S. District Judge.
United States v. Vaello-Madero, 356 F. Supp. 3d 208, 2019 U.S. Dist. LEXIS 20204 (D.P.R., Feb. 4, 2019)
residents, benefits, disabled, eligible, classification, district court, federal income tax, equal protection, blind, territory, rational basis, fiscal, federal treasury, contributions, programs, funds, federal government, categorical, proceeded, recipient, elderly, reasons, travel, tax status, disrupt, cases, equal protection guarantee, summary judgment, state interest, differential
Public Health & Welfare Law, Social Security, Disability Insurance & SSI Benefits, Eligibility, Civil Procedure, Appeals, Summary Judgment Review, Standards of Review, Constitutional Law, Equal Protection, Nature & Scope of Protection, Fundamental Rights, Procedural Due Process, Scope of Protection, Bill of Rights, Fundamental Freedoms, Assistance to Families, Child & Spousal Support, Governments, Courts, Judicial Precedent