United Statesv.Vaello Madero
The federal Supplemental Security Income program provides benefits to eligible residents of the fifty States and the District of Columbia but excludes residents of Puerto Rico. José Luis Vaello Madero received benefits while living in New York and later moved to Puerto Rico, where the Government sought repayment. He challenged the statutory exclusion under the Constitution’s equal-protection principles. The Supreme Court upheld the exclusion. It held that Congress may treat the Territories differently when legislating under the Territory Clause and that the distinction between residents of Puerto Rico and residents of the States was rationally related to legitimate fiscal and governmental interests. The Court rejected the argument that equal protection required identical federal benefits in Puerto Rico. Justice Gorsuch, joined by Justice Sotomayor, dissented and argued that the exclusion was inconsistent with the Constitution’s guarantee of equal treatment.
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