Schaller v. United States Social Security Administration

Leslie Schaller (plaintiff) was born and raised in Pennsylvania and received supplemental-security-income (SSI) benefits from the Social Security Administration (SSA) (defendant). Schaller had a degenerative genetic condition that would eventually leave her unable to care for herself. When this happened, Schaller believed her only two options were either to become a ward of the state of Pennsylvania or to move to Guam to live with family. Schaller also wanted to visit her family in Guam over Thanksgiving and Christmas, possibly for more than 30 days. However, under SSA policy, SSI recipients could receive benefits only while residing in one of the 50 states or the District of Columbia. The SSA would suspend payments if a recipient was outside that area for 30 days or more, including visiting a United States territory such as Guam. Schaller’s attorney contacted the SSA about continuing her benefits if she visited or moved to Guam. According to Schaller, an SSA representative said that Schaller could not receive SSI benefits in Guam and could not obtain an exception. Schaller sued the SSA in federal district court, alleging that the agency’s residency requirement violated equal-protection principles and her constitutional right to travel. The SSA moved to dismiss the lawsuit, arguing that Schaller lacked Article III standing because she had not yet suffered a concrete injury. The district court granted the motion and dismissed the case. Schaller appealed to the United States Court of Appeals for the Third Circuit.