Califano v. Torres

Background

Torres, Colon, and Vega received Supplemental Security Income (SSI) while living in Connecticut, Massachusetts, and New Jersey. When they moved to Puerto Rico, the Social Security Administration stopped their SSI payments because the 1972 SSI law defines “the United States” as the 50 States and the District of Columbia, excluding Puerto Rico. A federal court in Puerto Rico held that this geographic limit was unconstitutional as applied to these movers, and the Secretary of Health, Education, and Welfare appealed.

Reasoning

The core question was whether the constitutional right to travel requires people who move to Puerto Rico to keep the same SSI payments they had in a State. The Per Curiam opinion rejected the lower court’s view that newcomers must receive benefits superior to other Puerto Rico residents. The Court said monetary benefit laws get a strong presumption of constitutionality, Congress may treat Puerto Rico differently, and forcing continued payments would undermine the States’ ability to make uniform rules for their residents.

Real world impact

As a result, people who move from a State to Puerto Rico may lose SSI payments and instead be limited to older federal-state programs available on the island. The opinion records reasons the government advanced for exclusion: Puerto Rico’s unique tax status, an estimated $300 million yearly cost, and potential disruption of the island’s economy. The Court reversed the lower courts’ orders to continue SSI payments for these migrants.

Dissents or concurrances

Justice Brennan would have affirmed the lower courts, while Justice Marshall would have held further review and oral argument, showing not all Justices agreed with the per curiam reversal.