Puerto Rican citizenship
In 1994, Puerto Rican activist Juan Mari Brás flew to Venezuela and renounced his US citizenship before a consular agent in the US Embassy in Caracas. Mari Brás, through his renunciation of U.S. citizenship, sought to redefine Section VII as a source of law that recognized a Puerto Rican nationality separate from that of the United States. In December 1995, his denaturalization was confirmed by the US State Department. Among the arguments that ensued over his action was whether he would now be able to vote in elections in Puerto Rico. On November 18, 1997, the Supreme Court of Puerto Rico through its ruling in "Miriam J. Ramirez de Ferrer v. Juan Mari Brás" reaffirmed the Puerto Rican citizenship by ruling that U.S. citizenship was not a requirement to vote in Puerto Rico. According to the court's majority opinion, the Puerto Rican citizenship is recognized several times in the Puerto Rican constitution including section 5 of article III, section 3 of article IV, and section 9 of article V. In a 2006 memorandum, the Secretary of Justice of Puerto Rico concluded, based on the Mari Brás case, that the Puerto Rican citizenship is "separate and different" from the United States citizenship.
Puerto Rican migration to New York City
In 1902, the United States Treasury Department issued new immigration guidelines that changed the status of all Puerto Ricans to "foreigners." Isabel Gonzalez was a young single mother who was expecting her second child. Her fiancé, who was in New York, sent for her with the intention of getting married. When Gonzalez arrived in New York, she and all the Puerto Ricans who were with her, were detained in Ellis Island and denied entry. She was accused of being an alien and as an unwed parent she was deemed as a burden to the welfare system of the country. Gonzalez challenged the Government of the United States in the groundbreaking case "GONZALES v. WILLIAMS' (her surname was misspelled by immigration officials). The Supreme Court ruled that under the immigration laws González was not an alien, and therefore could not be denied entry into New York. It also stated that Puerto Ricans were not U.S. citizens, they were "noncitizen nationals." Gonzalez, who became an activist on behalf of all Puerto Ricans, paved the way for the Jones-Shafroth Act, which conferred United States citizenship on all citizens of Puerto Rico.