United States v. Vaello-Madero, No. 19-1390 (1st Cir. 2020)
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The First Circuit declared that exclusion of otherwise eligible residents of Puerto Rico from receiving the disability benefits that are granted to persons residing in the fifty States, the District of Columbia, and the Northern Mariana Islands under the Supplemental Security Income (SSI) provisions of Title XVI of the Social Security Act, 42 U.S.C. 1381-1383(f) is not rationally related to a legitimate government interest and is invalid.
While residing in New York, Defendant became eligible and commenced receiving SSI disability benefits. The benefits were discontinued when the Social Security Administration became award that Defendant had moved to Puerto Rico. The United States subsequently brought suit against Defendant seeking to collect the amount the SSA claimed was owed by Defendant due to the allegedly improper payment of SSI benefits since Defendant's relocation to Puerto Rico. Defendant raised as an affirmative defense that the exclusion of Puerto Rico residents from the SSI program violated the Equal Protection Clause. The district court granted summary judgment for Defendant, holding that Congress's actions in this case failed to pass rational basis constitutional muster. The First Circuit affirmed, holding that the Fifth Amendment forbids the categorial exclusion of Puerto Rico residents from SSI coverage.
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