Harris v. Rosario - 446 U.S. 651, 100 S. Ct. 1929 (1980)

Rule:

Congress, which is empowered under the Territory Clause of the Constitution, U.S. Const., Art. IV, § 3, cl. 2, to make all needful rules and regulations respecting the territory belonging to the United States, may treat Puerto Rico differently from states so long as there is a rational basis for its actions.

Facts:

Residents of Puerto Rico receiving assistance under the Aid to Families with Dependent Children program (AFDC) brought an action against the Secretary of Health, Education, and Welfare in the United States District Court for the District of Puerto Rico challenging, as violative of the Fifth Amendment's equal protection guarantee, 42 USCS 1308(a)(1) and 1396d(b), under which Puerto Rico receives less assistance than do the states. The court found the statutes to be unconstitutional insofar as their application resulted in a lower level of AFDC reimbursement for Puerto Rico. The Secretary appealed.

Issue:

Were 42 USCS 1308(a)(1) and 1396d(b), under which Puerto Rico receives less assistance under AFDC program (42 USCS 601 et seq.) than do the states, violative of equal protection?

Answer:

No.

Conclusion:

Reversing, the Court noted that Congress could treat Puerto Rico differently from states so long as there was a rational basis for its actions. The Court ruled that different treatment in the case under consideration was rationally grounded on three factors: Puerto Rican residents did not contribute to the federal treasury, the cost of treating Puerto Rico as a state under the statute would be high, and greater benefits could disrupt the Puerto Rican economy. These factors sufficed to form a rational basis for the challenged statutory classification applied in 42 U.S.C.S. §§ 1308(a)(1) and 1396d(b).