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U.S. v. Vaello-Madero

Court Type: U.S. Supreme Court
Status: Closed (Judgment)
Last Update: April 21, 2022

What's at Stake

Whether excluding Puerto Rico residents from the Supplemental Security Income (SSI) program violates the equal protection component of the 5th Amendment’s Due Process Clause.

The SSI program is designed to help needy people who are aged, blind, or disabled. Residents of Puerto Rico and most other territories, however, are not eligible for the program. Mr. Vaello-Madero was eligible for and received SSI benefits while living in New York. He later moved to Puerto Rico and, thus, unbeknownst to him, became ineligible for SSI. After years of collecting SSI in Puerto Rico, the U.S. Government learned of his move and sued Mr. Vaello-Madero to collect about $28,000 in benefits he received after he moved to Puerto Rico. Vaello-Madero defended the lawsuit on the grounds that the exclusion of Puerto Rico residents from the SSI program violated the Equal Protection guarantee of the 5th Amendment’s Due Process Clause.

The ACLU and others filed an amicus brief in the case supporting Mr. Vaello Madero. We argued the Court should apply a standard of review more meaningful than ‘rational basis’ given the composition of the people the SSI exclusion specifically targets: a politically disenfranchised marginalized group who are largely people of color. We also argued that, even under a ‘rational basis’ standard of review, Mr. Vaello-Madero should win because the Government’s arguments—that Puerto Rico’s tax status as a jurisdiction generally warrants discrimination against needy residents there; and that denying Puerto Rico residents this benefit promotes Puerto Rico’s autonomy—are irrational and thus fail even ‘rational basis’ review.

The Court ruled 8-1 against Mr. Vaello-Madero. Justice Sotomayor delivered an impassioned dissent highlighting the injustice of the majority’s decision.

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