This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
According to United States (Petitioner), according to United States (Petitioner), according to United States (Petitioner), United States v. Vaello‑Madero concerned whether Congress may constitutionally withhold Supplemental Security Income (SSI) benefits from residents of Puerto Rico.
The case also raised the question of whether the historic Insular Cases, which limit constitutional protections in U.S. territories, should continue to govern the treatment of Puerto Rico residents.
Background and question before the Court
According to MR. FERRE, the lower courts held that treating Vaello‑Madero differently because he resides in Puerto Rico was irrational.
The Court was asked whether the Territory Clause and the Insular Cases provide a rational basis for Congress to limit SSI benefits to Puerto Rico residents.
What each side argues
United States (Petitioner)
According to United States (Petitioner), according to United States (Petitioner), the United States argued that the Court of Appeals erred in holding that Congress’s decision not to extend SSI to Puerto Rico lacks a rational basis.
According to United States (Petitioner), according to United States (Petitioner), the United States further contended that Congress could reasonably consider fiscal differences when deciding which federal benefits to provide to Puerto Rico residents.
According to United States, deputy Solicitor General Curtis E. Gannon argued the case on behalf of the United States.
Mr. Gannon (Counsel for the United States)
According to Mr. GANNON, mr. Gannon asserted that the rational‑basis standard articulated in Torres and applied in Rosario permits Congress to consider the lower tax revenue generated in Puerto Rico.
Mr. Ferre (Defendant)
Mr. Ferre argued that it is irrational to treat Vaello‑Madero differently merely because he resides in Puerto Rico.
According to Mr. Ferre, mr. Ferre emphasized that the Court should consider the political powerlessness of Puerto Rico residents.
Curtis E. Gannon (Counsel)
According to Curtis E. Gannon, gannon maintained that the Territory Clause does not contain an expiration date, and that a different constitutional analysis would have applied if it did.
What happened at oral argument
Justice Thomas asked whether the Territory Clause alone provides a sufficient rational basis for Congress’s action.
According to Justice Sotomayor, justice Sotomayor inquired whether the Insular Cases are relevant to the litigation.
According to Justice Gorsuch, justice Gorsuch questioned whether the Insular Cases should be admitted as incorrectly decided.
What the Court decided
Justice Sotomayor filed a dissent, joining the Court’s opinion but urging that the Insular Cases be overruled.
Why it matters
Residents of Puerto Rico are generally exempt from most federal income, gift, estate, and excise taxes, highlighting a broader pattern of differential treatment.
Justice Sotomayor argued that the Insular Cases rest on a rotten foundation and should be overruled.
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 0f0322c934c4240c61cc-r1-2975fcfa2803e7c4.pdforal argument transcript
- 2db108ef05057b212383-r1-d82394826c2026eb.pdfopinion
Guide generated September 28, 2026. Automated validation accepted this version.