Puerto Rican citizenship
In 1952, upon U.S. Congress approving the Constitution of the Commonwealth of Puerto Rico, also reaffirmed that Puerto Rican citizenship continued in full force. This was further reaffirmed in 2006 while the U.S. Senate probed into the President's Task Force on Puerto Rico's status. In 1953, U.S Ambassador Henry Cabot Lodge Jr., in a memorandum sent to the United Nations, recognized that "the people of Puerto Rico continue to be citizens of the United States as well as of Puerto Rico."
Juan Mari Brás
In rejecting the renunciation, the Department noted that the Plaintiff in "Colón" demonstrated no intention of renouncing all ties to the United States, i.e., claiming to reject his United States citizenship, but nevertheless wishing to remain a resident of Puerto Rico. The Plaintiff's response was to claim a fundamental distinction between United States and Puerto Rican citizenship. The United States Department of State position asserted that renunciation of U.S. citizenship must entail renunciation of Puerto Rican citizenship as well. The court does decide to not enter to the merits of the citizenship issue; however the U.S. District Court for the District of Columbia rejected Colón's petition for a writ of mandamus directing the Secretary of State to approve a Certificate of Loss of Nationality in the case because the plaintiff wanted to retain one of the primary benefits of U.S. citizenship while claiming he was not a U.S. citizen. The Court described the plaintiff as a person, "claiming to renounce all rights and privileges of United States citizenship, [while] Plaintiff wants to continue to exercise one of the fundamental rights of citizenship, namely to travel freely throughout the world and when he wants to, return and reside in the United States." The court based this decision on the Immigration and Nationality Act section 8 U.S.C. § 1101(a)(38), which defines the term "United States", and evince that Puerto Rico is a part of the United States for such purposes.