Califano v. Torres
435 U.S. 1, 1978 U.S. LEXIS 62, 55 L. Ed. 2d 65 (1978)
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Rule of Law:
The constitutional right to travel does not require Congress to pay federal benefits, such as Supplemental Security Income (SSI), to an individual who moves to a jurisdiction, like Puerto Rico, where residents are not otherwise eligible for those benefits.
Facts:
- In 1972, Congress amended the Social Security Act to create the Supplemental Security Income (SSI) program for qualified aged, blind, and disabled persons.
- The Act's definitional section limited eligibility to residents of the "United States," defined as the 50 States and the District of Columbia, thereby excluding residents of Puerto Rico.
- Appellee Torres was receiving SSI benefits while residing in Connecticut.
- Appellees Colon and Vega were receiving SSI benefits while residing in Massachusetts and New Jersey, respectively.
- Torres, Colon, and Vega all subsequently moved from their respective states to Puerto Rico.
- Upon establishing residency in Puerto Rico, the Social Security Administration discontinued their SSI benefits because they no longer resided within the program's geographic limits.
Procedural Posture:
- Appellee Torres sued the Secretary of Health, Education, and Welfare in the U.S. District Court for the District of Puerto Rico.
- A three-judge panel of the district court held that the SSI program's geographic limitation was unconstitutional as applied to Torres.
- Appellees Colon and Vega filed similar lawsuits in the same district court.
- A single district judge, following the Torres precedent, granted an injunction preventing the government from terminating Colon's and Vega's benefits.
- The Secretary of Health, Education, and Welfare (appellant) appealed these adverse decisions directly to the Supreme Court of the United States.
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Issue:
Does the Social Security Act's exclusion of Puerto Rico residents from the Supplemental Security Income (SSI) program, which results in the termination of benefits for individuals who move from an eligible U.S. state to Puerto Rico, unconstitutionally burden the right to travel?
Opinions:
Majority - Per Curiam
No. The Social Security Act's geographic limitations on SSI eligibility do not unconstitutionally burden the right to travel. The constitutional right of interstate travel ensures that new residents are treated the same as existing residents of a state, not that they are entitled to benefits superior to those enjoyed by the local population. Previous cases like Shapiro v. Thompson struck down laws that denied new residents benefits available to long-term residents. This case presents the opposite scenario, where appellees seek to continue receiving benefits that are unavailable to any other resident of Puerto Rico. To hold otherwise would imply that individuals could carry benefit eligibility from a former state indefinitely, a doctrine that would undermine the power of each state to enact uniform laws for its residents. Because this is a social welfare statute providing monetary benefits, it is entitled to a strong presumption of constitutionality and is subject to rational basis review, which it satisfies.
Dissenting - Justice Brennan
Justice Brennan would affirm the lower court's decision, finding the statute unconstitutional.
Dissenting - Justice Marshall
Justice Marshall would not have decided the case summarily and instead would have noted probable jurisdiction to set the case for full briefing and oral argument.
Analysis:
This decision significantly clarifies the scope of the constitutional right to travel, distinguishing it from a right to 'export' benefits. It establishes that the right protects against durational residency requirements that penalize newcomers, but does not create an entitlement to maintain benefits upon moving to a jurisdiction where those benefits are not offered. The ruling reinforces Congress's broad authority under rational basis review to create geographic classifications in social welfare legislation. Furthermore, it affirms the unique legal and political status of Puerto Rico, allowing Congress to legislate for the territory differently than for the states, provided there is a rational basis for doing so.
