United States v. Vaello Madero

José Luis Vaello Madero, a U.S. citizen, received Supplemental Security Income (SSI) benefits while residing in New York. After he moved to Puerto Rico, the Social Security Administration terminated his benefits because federal law categorically excludes Puerto Rico residents from the SSI program. Vaello Madero sued, and the U.S. Court of Appeals for the First Circuit ruled that the exclusion violated the equal protection guarantee of the Fifth Amendment's Due Process Clause. The Supreme Court reversed, holding 8-1 that Congress has broad authority under the Territory Clause to treat Puerto Rico differently and that the differential treatment is supported by a rational basis, such as the territory’s unique tax and fiscal relationship with the federal government. The decision confirmed that residents of Puerto Rico are not constitutionally entitled to SSI benefits.

The Supreme Court reversed the First Circuit, ruling that the denial of SSI benefits to Puerto Rico residents has a rational basis and does not violate the Fifth Amendment. Justice Kavanaugh delivered the opinion of the Court; Justice Thomas and Justice Gorsuch filed concurring opinions; Justice Sotomayor was the sole dissenter.

Whether Congress's statutory exclusion of Puerto Rico residents from the Supplemental Security Income program violates the equal protection component of the Fifth Amendment's Due Process Clause.

The ruling reinforced Congress's broad power to exclude U.S. territories from federal public benefits programs, directly affecting an estimated 300,000 Puerto Rico residents. It ignited renewed debate over Puerto Rico's territorial status and the disparate treatment of American citizens in the territories, highlighting ongoing calls for political and civil rights reforms.