In "Harris v. Rosario", 446 U.S. 651 (1980), the Court applied "Califano v. Torres", 435 U.S. 1 (1978) in a succinct per curiam order, holding that less aid to Puerto Rican families with dependent children did not violate the Equal Protection Clause, because in U.S. territories Congress can discriminate against its citizens applying a rational basis review.