United States v. Vaello-Madero - 956 F.3d 12 (1st Cir. 2020)

Rule:

The Fifth Amendment does not permit the arbitrary treatment of individuals who would otherwise qualify for Supplemental Security Income but for their residency in Puerto Rico.

Facts:

Appellee claimed 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 under the Supplemental Security Income (SSI) provisions of Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1383f, contravened 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 authorized the termination of these payments if the recipient resides more than thirty consecutive days outside the "United States" as so defined. 

Issue:

Did the categorical exclusion of otherwise eligible Puerto Rico residents from SSI pursuant to 42 U.S.C.S. § 1382c violate the Equal Protection Clause of the Fifth Amendment?

Answer:

Yes.

Conclusion:

The court held that the categorical exclusion of otherwise eligible Puerto Rico residents from SSI pursuant to 42 U.S.C.S. § 1382c violated the Equal Protection Clause of the Fifth Amendment because it was not rationally related to a legitimate government interest, particularly as the cost of including Puerto Rico residents in the SSI program and the tax status of Puerto Rico residents was not a rational basis for their exclusion from the program. In addition, other theoretical reasons for this differential treatment did not establish the required rational basis for this statutory exclusion.