Summary
The Supreme Court upheld federal statutory requirements that aliens be lawfully admitted for permanent residence and continuously reside in the United States for five years to qualify for Medicare Part B. The Court held that Congress may distinguish between citizens and aliens, and among categories of aliens, when administering federal welfare benefits, applying a deferential standard of review. The Court also addressed jurisdiction and exhaustion requirements under the Social Security Act.
Topics
Practice areas
Questions Presented
- Whether the District Court had jurisdiction over Espinosa's claim despite his failure to complete the ordinary administrative review process.
- Whether Congress may condition an alien's eligibility for Medicare Part B benefits on lawful admission for permanent residence and five years of continuous residence in the United States.
- Whether 42 U.S.C. § 1395o(2)(B) deprived the appellees of liberty or property without due process of law.
Holdings
- The District Court had jurisdiction over Espinosa's claim because his application had been filed while the action was pending, the Secretary stipulated that no factual issues remained and that the application could not be granted under the statute, and that stipulation was tantamount to a final decision denying the application and constituted a waiver of exhaustion.
- Congress may distinguish between citizens and aliens, and among different classes of aliens, when determining eligibility for federal welfare benefits; such classifications are constitutional so long as they are not wholly irrational.
- The requirements that an alien be lawfully admitted for permanent residence and have resided continuously in the United States for five years did not deprive the appellees of liberty or property without due process of law.
Key quotations
“We conclude, as we did in Salfi, that the Secretary's submission of the question for decision on the merits by the District Court satisfied the statutory requirement of a hearing and final decision.” (426 U.S. at 77)
“In short, it is unquestionably reasonable for Congress to make an alien's eligibility depend on both the character and the duration of his residence.” (426 U.S. at 82-83)
“We hold that § 1395o (2) (B) has not deprived appellees of liberty or property without due process of law.” (426 U.S. at 87)
Factual background
The appellees were resident aliens over age 65 who had been denied or were unable to obtain Medicare Part B supplemental medical insurance because they did not satisfy the statutory requirements of lawful admission for permanent residence and five years' continuous residence in the United States. Diaz and Clara were Cuban refugees remaining at the Attorney General's discretion, while Espinosa had been admitted for permanent residence but had not completed five years of residence. The Medicare statute allowed citizens aged 65 or older to enroll but limited alien eligibility to lawful permanent residents who had continuously resided in the United States for the preceding five years.
Procedural history
Diaz filed a class action in the United States District Court for the Southern District of Florida challenging the denial of Medicare Part B enrollment to aliens who were not lawful permanent residents or who had not continuously resided in the United States for five years. Clara and Espinosa were added as plaintiffs, and the District Court denied the Secretary's motion to dismiss for failure to exhaust administrative remedies. On cross-motions for summary judgment, the District Court held the five-year residence requirement unconstitutional and enjoined the Secretary from denying enrollment. The Secretary appealed directly to the Supreme Court, which noted probable jurisdiction, ordered reargument, and reversed.