Puerto Rican citizenship
On March 2, 1917, the Jones–Shafroth Act was signed, collectively making Puerto Ricans United States citizens without rescinding their Puerto Rican citizenship. In 1922, the U.S. Supreme court in the case of "Balzac v. Porto Rico" ruled that the full protection and rights of the U.S constitution do not apply to residents of Puerto Rico until they come to reside in the United States proper. Luis Muñoz Rivera, who participated in the creation of the Jones-Shafroth Act, gave a speech in the U.S. House floor that argued in favor of Puerto Rican citizenship. He declared that "if the earth were to swallow the island, Puerto Ricans would prefer American citizenship to any citizenship in the world. But as long as the island existed, the residents preferred Puerto Rican citizenship." The Jones Act allowed locals to renounce the United States citizenship and remain exclusively Puerto Rican citizens, at the cost of being stripped of the right to vote. Despite these arbitrary limitations, 287 residents completed the process to forfeit the statutory recognition.
Juan Mari Brás
On 15 May 1996, Miriam J. Ramírez de Ferrer, a pro-statehood attorney, presented a formal complaint against Mari Brás before the Mayaguez Electoral Board, where Mari Brás was registered to vote, so he could not vote as he was not a U.S. citizen. It was denied because the Board had no jurisdiction. Upon appeal by Ramírez, the Puerto Rico Electoral Board subsequently supported the decision of the Mayaguez Board. Ramírez subsequently took the matter to the Puerto Rico Superior Court (Tribunal de Primera Instancia, Sala Superior de San Juan). As a result, the Superior Court declared unconstitutional Articles 2.003 y 2.023 of Puerto Rico's Electoral Law as they required U.S. citizenship as a condition to vote in Puerto Rico's elections. On November 18, 1997, Ramírez then took Mari Brás before the Puerto Rico Supreme Court alleging that if he had renounced his United States citizenship, then he also had renounced his right to vote in the local Puerto Rican elections. The Puerto Rican Supreme Court sided with Mari Brás, finding that "as a citizen of Puerto Rico" Mari Brás was eligible to vote.