Mathews v. Diaz
Headline: Court upholds Congress’ rules requiring lawful permanent residence and five years’ continuous U.S. residence before older resident aliens may enroll in Medicare Part B, limiting benefits for many noncitizens.
Holding: The Court held that Congress may require aliens to be admitted for permanent residence and to have lived continuously in the United States for five years before enrolling in Medicare Part B, reversing the lower court.
- Permits denial of Medicare Part B to recent or nonpermanent resident aliens.
- Affects many older noncitizens, including paroled refugees and recent immigrants.
- Leaves decisions about expanding benefits to Congress and the Executive branch.
Summary
Background
Three older resident aliens sued after being denied enrollment in Medicare Part B. Two plaintiffs are Cuban refugees who remain here at the Attorney General’s discretion; the third is an alien admitted for permanent residence in 1971. The denials were based on a federal law that gives citizens immediate eligibility but requires aliens to be lawfully admitted for permanent residence and to have lived continuously in the United States for five years before enrolling.
Reasoning
The Court addressed whether Congress may treat citizens and different groups of aliens differently when deciding who may receive federal welfare benefits. The Justices explained that the Fifth Amendment protects aliens from government deprivation but that Congress has broad authority over immigration and may make classifications based on the character and duration of an alien’s ties to the country. The Court applied a narrow standard of review for federal immigration-related classifications, found the two requirements not irrational, and concluded the plaintiffs had not shown a principled reason to prefer a different rule. The Court also treated procedural questions about administrative exhaustion as satisfied because the Secretary stipulated that no factual issues remained and that applications would be denied.
Real world impact
Because the Court reversed the District Court and upheld the statute, older aliens who are not lawfully admitted for permanent residence or who have not lived in the United States continuously for five years may be denied Medicare Part B. The opinion notes that millions of aliens live in the United States and over 440,000 Cuban parolees were relevant to the Court’s view of congressional flexibility. The ruling leaves choices about expanding eligibility to Congress and the Executive.
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