Puerto Rican citizenship
On April 12, 1900, the United States Congress enacted the Foraker Act of 1900, which replaced the governing military regime in Puerto Rico with a civil form of government. Section VII of this act created a Puerto Rican citizenship for the residents "born in Puerto Rico and, therefore, subject to its jurisdiction." The Puerto Rican citizenship replaced the Spanish citizenship that Puerto Ricans held at the time in 1898. Such Puerto Rican citizenship was granted by Spain in 1897. This citizenship was reaffirmed by the United States Supreme Court in 1904 by its ruling in which denied that Puerto Ricans were United States citizens and labeled them as noncitizen nationals. In a 1914 letter of refusal to the offer of U.S. citizenship and addressed to both the President of the United States and the U.S. Congress, the Puerto Rico House of Delegates stated ""We, Porto Ricans, Spanish-Americans, of Latin soul ... are satisfied with our own beloved Porto Rican citizenship, and proud to have been born and brethren in our own motherland."" The official 1916 Report by the American colonial governor of Puerto Rico to the U.S. Secretary of War (the former name for the Department of Defense), addresses both citizenships, the Puerto Rican citizenship and United States citizenship, in the context of the issuance of passports, further evidencing that the Puerto Rican citizenship did not disappear when the Americans took over the island in 1898.
Puerto Rican immigration to Hawaii
Manuel Olivieri Sanchez, a court interpreter at the time, became enraged in what he viewed as a violation of the civil rights of his fellow countrymen. He encouraged his fellow Puerto Ricans to protest by telling them that "If you are not allowed to vote, don't answer the draft call". Olivieri Sanchez led a legal battle for the recognition of the Hawaiian Puerto Ricans as citizens of the United States. In the first legal battle the lower court ruled in favor of the county clerk, however Olivieri Sanchez did not give up the fight and took the case before the Territorial Supreme Court, which reversed the decision of the lower court, granting the Puerto Ricans of Hawaii their United States citizenship.