The aff links---in order to extend Social Security, you have to overturn insular cases.

Gonzalez 21 (Gonzalez, Alejandro J. Anselmi. J.D. Candidate @ the University of Miami, Received their B.A. In Poli Sci and Psychology from WashU, St. Louis. "The Flag Can Travel but the Constitution Must Ask Permission: How the First Circuit and the District for Puerto Rico Commit to Equal Protection without Abandoning the Insular Cases Doctrine." University of Miami Inter-American Law Review, vol. 53, no. 1, Winter/Spring 2021. HeinOnline. https://heinonline.org/HOL/Page?handle=hein.journals/unmialr53&collection=journals&id=97&startid=&endid=168. Accessed 7/24/23)

i. The First Circuit Indirectly Addresses the Relevance of the Insular Cases Through Its Treatment of Califano and Harris

To fulfill the rational basis requirements, the federal government argued that exclusion of Puerto Rican residents serves legitimate governmental interests because of "the unique tax status of Puerto Rico and the costs of extending the program" to its residents. 296 The federal government also proffered Califano v. Gautier Torres, a Supreme Court decision from 1978, as a basis on which to exclude Puerto Rican residents from SSI 297 Califano had reversed a district court judgment holding that denial of SSI payments to "a recipient who acquired them while a resident of Connecticut, but was thereafter denied them by reason of his moving to Puerto Rico," contravened his "constitutional right to travel." 298 According to the First Circuit, the federal government regarded Califano as valuable precedent because it involved a statutory provision establishing government benefits and is thus entitled to "a strong presumption of constitutionality." 299

The federal government also relied on Harris v. Rosario, in which the Supreme Court held that Congress derived sufficient authority from the Territorial Clause to "treat Puerto Rico differently from States so long as there is a rational basis for its actions."300 According to the Supreme Court, three factors enunciated in Califano were enough to fulfill the rational basis test and uphold the exclusion of Puerto Rican residents from SSI. (1) Puerto Rican residents do not pay federal taxes, (2) the cost of extending SSI to the Island would be high, and (3) the increased benefits would "disrupt the Puerto Rican economy."301

The First Circuit underscores that, while still valid Supreme Court precedent, Califano and Harris dealt with the right to travel and with block grants for the Aid to Families with Dependent Children Program, respectively, not with the "validity of alleged discriminatory treatment ... as required by the SSI program under the prism of equal protection." 30 2 As such, neither case was controlling Supreme Court precedent precluding the Appellee's claim that his exclusion from SSI contravened equal protection guarantees. 303 At the same time, despite Califano and Harris, the First Circuit maintains that the federal government must still have a rational justification to make suspect legislative classification, or else the rational basis test might become a "nullity" and "suspend the operation of the Equal Protection Clause in the field of social welfare law . ... "304 Thus, the First Circuit finds that equal protection principles survive Califano and Harris, and can be grounds to decide the Appellee's claim in Vaello-Madero despite valid Supreme Court precedent. 305