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United States v. Vaello-Madero

United States v. Vaello-Madero

Supreme Court of the United States

November 9, 2021, Argued; April 21, 2022, Decided

No. 20-303.

Opinion

Justice Kavanaugh delivered the opinion of the Court.

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 [*4]  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 Territory Clause of the Constitution states that Congress may “make all needful Rules and Regulations respecting the Territory . . . belonging to the United States.” Art. IV, §3, cl. 2. The text of the Clause affords Congress broad authority to legislate with respect to the U. S. Territories.

Exercising that authority, Congress sometimes legislates differently with respect to the Territories, including Puerto Rico, [*5]  than it does with respect to the States. That longstanding congressional practice reflects both national and local considerations. In tackling the many facets of territorial governance, Congress must make numerous policy judgments that account not only for the needs of the United States as a whole but also for (among other things) the unique histories, economic conditions, social circumstances, independent policy views, and relative autonomy of the individual Territories.

Of relevance here, Congress must decide how to structure federal taxes and benefits for residents of the Territories. In doing so, Congress has long maintained federal tax and benefits programs for residents of Puerto Rico and the other Territories that differ in some respects from the federal tax and benefits programs for residents of the 50 States.

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2022 U.S. LEXIS 2094 *; __ S.Ct. __; 2022 WL 1177499

UNITED STATES, PETITIONER v. JOSE LUIS VAELLO MADERO

Notice: The pagination of this document is subject to change pending release of the final published version.

Prior History:  [*1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT

United States v. Vaello-Madero, 956 F.3d 12, 2020 U.S. App. LEXIS 11358, 2020 WL 1815967 (1st Cir. P.R., Apr. 10, 2020)

Disposition: 956 F. 3d 12, reversed.

CORE TERMS

residents, citizenship, Territories, benefits, Cases, federal government, eligible, programs, civil rights, rights, us citizen, recipients, taxes, rational basis, privileges, Islands, equal protection, due process, federal tax, classification, funds, terms, segregation, Treasury, equal protection guarantee, Republicans, colonies, declare, unincorporated territory, substantive due process

Constitutional Law, Relations Among Governments, Federal Territory & New States, Public Health & Welfare Law, Social Security, Disability Insurance & SSI Benefits, Eligibility, Tax Law, Federal Tax Administration & Procedures, Interpretation of Federal Tax Statutes, Congressional Duties & Powers, Spending & Taxation