United States v. Vaello Madero
United States v. Vaello Madero | |
---|---|
Argued November 9, 2021 Decided April 21, 2022 | |
Full case name | United States v. Jose Luis Vaello Madero |
Docket no. | 20-303 |
Citations | 596 U.S. ___ (more) |
Argument | Oral argument |
Decision | Opinion |
Holding | |
The Constitution does not require Congress to extend Supplemental Security Income benefits to residents of Puerto Rico. | |
Court membership | |
| |
Case opinions | |
Majority | Kavanaugh, joined by Roberts, Thomas, Breyer, Alito, Kagan, Gorsuch, Barrett |
Concurrence | Thomas |
Concurrence | Gorsuch |
Dissent | Sotomayor |
Laws applied | |
U.S. Const. art. IV U.S. Const. amend. V |
United States v. Vaello Madero, 596 U.S. ___ (2022), was a United States Supreme Court case related to the constitutionality of the exclusion of United States citizens residing in Puerto Rico from the Supplemental Security Income program. In an 8–1 decision, the Court ruled that as Congress had been granted broad oversight of United States territories by Article Four of the United States Constitution, the exclusion of the territories by Congress from programs like Supplemental Security Income did not violate the Due Process Clause of the Fifth Amendment.
Background
The Supplemental Security Income (SSI) program is a benefit for older or disabled citizens who are unable to take care of themselves. As established by Congress, the benefits available to all citizens of the 50 states, the District of Columbia, and the Northern Mariana Islands, but does not cover residents of the other United States territories, including Puerto Rico.[1]
Jose Luis Vaello Madero was a recipient of SSI benefits while living in New York, and then moved to Puerto Rico in 2013. He continued to receive SSI benefits, but eventually the government discovered his new residence, terminated the SSI benefits and sought to recover approximately $28,000 he had improperly received while in Puerto Rico.[1] A federal district judge and the United States Court of Appeals for the First Circuit found that this exclusion violated the equal protection principle of the Fifth Amendment to the United States Constitution's due process clause, which was first established in Bolling v. Sharpe.[2]
Supreme Court
Certiorari was granted in the case on March 1, 2021.[3] The argument in this case was held on November 9, 2021, and the decision was announced on April 21, 2022. Associate Justice Brett Kavanaugh delivered the opinion of the court. Associate Justices Clarence Thomas and Neil Gorsuch wrote concurrences. Associate Justice Sonia Sotomayor wrote a dissenting opinion.[4]
Opinion of the Court
Justice Kavanaugh's opinion represented the views of eight justices; all sitting justices except Justice Sotomayor.
Concurrences
Both Justice Thomas and Justice Gorsuch joined the opinion of the Court in full.
Justice Thomas's concurrence
Justice Thomas noted that he previously has joined and written opinions applying the "doctrine" that the Fifth Amendment's Due Process Clause has an "equal protection component" that is similar to the Fourteenth Amendment's Equal Protection Clause. However, he "now doubt[s] whether it comports with the
Section I
In Section I, Justice Thomas discusses how the Supreme Court has previously interpreted the Fifth Amendment's Due Process Clause and lists his criticisms of the logic behind
Section II
In Section II, Justice Thomas discusses his alternative reasoning for Bolling v. Sharpe (1954), namely the Citizenship Clause in the Fourteenth Amendment. He argues that citizenship was historically associated with equality so that "the absence or presence of one entailed the absence or presence of the other".[15] In Section II-A, Thomas discusses how even Chief Justice Roger B. Taney's infamous opinion in Dred Scott v. Sandford (1857) demonstrated the connection between citizenship and equal protection when Taney, "erroneously in [Thomas's] view", claimed that the "States' longstanding and widespread practice of denying free blacks equal civil rights conclusively showed that blacks were not citizens entitled to various constitutional protections".[16] Thomas explains that even after the Civil War and the Thirteenth Amendment, southern states refused to acknowledge black people as citizens and refused to respect their rights. In response, Congress enacted the Civil Rights Act of 1866 and sent the Fourteenth Amendment to the states. Justice Thomas cited the debates surrounding these laws as evidence that the Citizenship Clause of the Fourteenth Amendment may include an equal protection component.[17] In Section II-B, Justice Thomas briefly discusses various decisions from 1868 (after the ratification of the Fourteenth Amendment) to 1896 (the year Plessy v. Ferguson was decided) that support the view that the Citizenship Clause of the Fourteenth Amendment was understood by some justices on the Supreme Court (especially John Marshall Harlan) to prohibit the federal government from denying equal protection of the laws.[18] Ultimately, Thomas concludes, "Rather than continue to invoke the Fifth Amendment's Due Process Clause to justify Bolling, in an appropriate case, we should more carefully consider whether this interpretation of the Citizenship Clause would yield a similar, and more supportable, result".[19]
Justice Gorsuch's concurrence
Justice Gorsuch began by claiming that "it is past time to acknowledge the gravity of this error and admit what we know to be true: The
Dissent
Justice Sotomayor dissented because Congress's reasoning for excluding Puerto Rico from the Supplemental Security Income program fails rational basis review, and therefore violates the equal protection component of the Fifth Amendment's Due Process Clause.[25] In Section I, Sotomayor describes the changes from the previous state-by-state programs partially funded by the federal government to the SSI program which was uniform and fully funded and controlled by the federal government. Specifically, "Congress displaced the States" in this one particular program. She noted that the SSI statute defined residents of the United States to exclude Puerto Rico. However, she noted Congress's frequent choices to define the "United States" as including Puerto Rico. She also emphasized that residents of Puerto Rico are United States citizens.[26] In Section II, Sotomayor describes the history of the case, including what caused the lawsuit and what lower courts had decided.[27] In Section III, Sotomayor describes how even assuming rational basis review, a "deferential" but not "toothless" standard, the decision to exclude Puerto Rico residents from SSI is impermissible. She also notes her agreement with Justice Gorsuch that the Court should consider overruling the Insular Cases in the future.[28] In Section III-A, Sotomayor explains that "under the current system, the jurisdiction in which an SSI recipient resides has no bearing at all on the purposes or requirements of the SSI program", because the SSI program is a "direct relationship" between the individual and the federal government. Sotomayor claims this feature of the program means that location is not a rational basis for classification in this situation. She also notes that "by definition, SSI recipients pay few if any taxes at all", casting doubt on the majority's reliance on the tax burdens and benefits as a rational basis for classification.[29] In Section III-B, Sotomayor questions whether this holding may apply to states; for instance, if "Congress could exclude needy residents of Vermont, Wyoming, South Dakota, North Dakota, Montana, and Alaska". She also states that the federal government had not brought to the Court's attention any other program that "operates in such a uniform, nationalized, and direct manner".[30] Sotomayor concludes that while it is true that the Constitution gives Congress the authority to "make all needful Rules and Regulations" for territories, that does not allow Congress to ignore the "constitutional command that it treat United States citizens equally".[31]
See also
References
- ^ a b Liptak, Adam (April 21, 2022). "Supreme Court Rules on Stolen Art, Signs and Puerto Rico's Status". The New York Times. Retrieved April 24, 2022.
- ^ Howe, Amy (March 1, 2021). "Court will review Puerto Rico's ineligibility for federal benefits program". SCOTUSblog. Retrieved July 5, 2021.
- ^ "United States v. Vaello Madero". SCOTUSblog. Retrieved August 18, 2021.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. Retrieved April 8, 2023.
- ^ a b "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 2. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 3. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 4. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 5. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 6-7. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 8. Retrieved April 8, 2023.
- ^ a b "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 9. Retrieved April 8, 2023.
- ^ a b "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 24. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 9-11. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 12-14. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 14. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 15. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 16-18. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 18-22. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 22-23. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. pp. 24–26. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. pp. 26–28. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. pp. 28–29. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. pp. 29–31. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. pp. 31–33. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 34. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 34-36. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 37-38. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 38-39. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 39-41. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 42. Retrieved April 8, 2023.
- ^ "Supreme Court: United States v. Vaello Madero" (PDF). April 21, 2022. p. 43. Retrieved April 8, 2023.
External links
- Text of United States v. Vaello Madero, 596 U.S. ___ (2022) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)