Harris v. Rosario
446 U.S. 651, 64 L. Ed. 2d 587, 1980 U.S. LEXIS 106 (1980)
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Rule of Law:
Under its constitutional authority over United States territories, Congress may treat Puerto Rico differently from states in federal social welfare programs, so long as there is a rational basis for the legislative distinction.
Facts:
- The Aid to Families with Dependent Children (AFDC) program was a federal initiative providing financial assistance to states and territories for needy dependent children.
- A federal statute, 42 U.S.C. §§ 1308 and 1396d(b), established the funding formula for the AFDC program.
- Under this statute, the Commonwealth of Puerto Rico received less financial assistance and reimbursement than the 50 states.
- Appellees were residents of Puerto Rico who received benefits through the AFDC program.
- As a result of the statutory funding cap, these residents received a lower level of aid than similarly situated residents in the 50 states.
Procedural Posture:
- A class of AFDC recipients residing in Puerto Rico (Appellees) filed a lawsuit against the Secretary of Health, Education, and Welfare (Appellant) in the U.S. District Court for the District of Puerto Rico.
- The plaintiffs challenged the constitutionality of federal statutes that provided less AFDC funding to Puerto Rico than to the states.
- The U.S. District Court, a court of first instance, ruled in favor of the plaintiffs, holding that the lower funding level violated the Fifth Amendment's equal protection guarantee.
- The Secretary of Health, Education, and Welfare appealed this decision directly to the Supreme Court of the United States.
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Issue:
Does a federal statute that provides a lower level of reimbursement to Puerto Rico than to the states under the Aid to Families with Dependent Children (AFDC) program violate the equal protection component of the Fifth Amendment's Due Process Clause?
Opinions:
Majority - Per Curiam
No. The lower level of AFDC reimbursement provided to Puerto Rico does not violate the Fifth Amendment's equal protection guarantee. Congress is empowered by the Territory Clause of the Constitution to make all needful rules and regulations for U.S. territories. Under this authority, Congress may treat Puerto Rico differently from the states as long as there is a rational basis for its actions. Citing its recent decision in Califano v. Torres, the Court found three factors that provided a rational basis for the disparate treatment: 1) residents of Puerto Rico do not contribute to the federal treasury through federal income taxes; 2) the cost of treating Puerto Rico as a state for these benefits programs would be substantial; and 3) providing a greater level of benefits could disrupt the Puerto Rican economy. These considerations are sufficient to justify the statutory classification under the rational basis standard of review.
Dissenting - Marshall, J.
Yes. The Court's summary disposition of this important constitutional question is improper, and the rational basis standard may not be the appropriate level of scrutiny. Puerto Ricans are United States citizens, and the Court has previously held that various constitutional protections, including the equal protection guarantee, apply to them. The majority's sole reliance on Califano v. Torres is misplaced, as that case concerned the right to travel, and its discussion of equal protection was dicta in a footnote. Furthermore, the rationales provided are troubling; suggesting that aid should be withheld from the neediest to avoid disrupting the local economy is a questionable justification for discrimination. The issue of the constitutional relationship between Puerto Rico and the United States deserves full briefing and oral argument, not a rushed summary judgment.
Analysis:
This decision reaffirms Congress's broad authority under the Territory Clause to legislate for U.S. territories, including treating them differently from states in federal benefit programs. It solidifies the application of the highly deferential 'rational basis' test for such distinctions, making it very difficult to challenge them on equal protection grounds. The ruling has had a lasting impact, providing the constitutional justification for ongoing disparities in federal funding for social welfare, healthcare, and other programs in Puerto Rico and other U.S. territories, perpetuating economic inequalities between citizens in territories and those in the states.
