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a Research Service
Equal Protection Does Not Mean Equal SSI
Benefits for Puerto Rico Residents, Says
Supreme Court
April 28, 2022
On April 21, 2022, the U.S. Supreme Court decided United States v. Vaello-Madero, a case asking
whether the equal protection guarantee in the U.S. Constitution's Fifth Amendment requires Congress to
provide the same federal benefits (specifically, Supplemental Security Income [SSI] benefits for the aged,
blind, and disabled) to Puerto Rico residents as to residents of the 50 states. In a ruling that reaffirmed
Congress's constitutional authority to treat territorial residents differently as long as it has a rational basis
for doing so, the Supreme Court determined that the Fifth Amendment does not require Congress to
extend SSI benefits to Puerto Rico residents. The Supreme Court's decision reversed the determinations
of both lower courts. This Sidebar discusses the legal arguments advanced before the Supreme Court
before analyzing considerations for Congress.
Background
Facts of the Case
While living in New York, Jose Luis Vaello-Madero became eligible for, and began receiving, SSI
disability benefits. He later moved to Puerto Rico, where he continued to receive SSI payments. By law, a
person must be a resident of the United States to be eligible for SSI benefits. For purposes of the relevant
statute, Congress defined United States to mean the 50 states and the District of Columbia. Congress
extended SSI eligibility to residents of the Northern Mariana Islands in 1976 but has not done so for
Puerto Rico or other U.S. territories. Accordingly, the Social Security Administration sued Vaello-Madero
to recover the payments he received while living in Puerto Rico. In response, Vaello-Madero argued that
excluding Puerto Rico residents from SSI eligibility was unconstitutional-specifically, that it violated his
constitutional right to equal protection under the law.
Congressional Research Service
https://crsreports.congress.gov
LSB10737
CRS Legal Sidebar
Prepared for Members and
Committees of Congress](ViewImageLocal?handle=hein.crs/govefqq0001&div=1&collection=&method=preview&ext=.png&size=3)
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