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 Rico
In 1993 the United States Court of Appeals for the Eleventh Circuit stated that Congress may unilaterally repeal the Puerto Rican Constitution or the Puerto Rican Federal Relations Act and replace them with any rules or regulations of its choice. In a 1996 report on a Puerto Rico status political bill, the U.S. House Committee on Resources stated, "Puerto Rico's current status does not meet the criteria for any of the options for full self-government under Resolution 1541" (the three established forms of full self-government being stated in the report as (1) national independence, (2) free association based on separate sovereignty, or (3) full integration with another nation on the basis of equality). The report concluded that Puerto Rico "... remains an unincorporated colony and does not have the status of 'free association' with the United States as that status is defined under United States law or international practice", that the establishment of local self-government with the consent of the people can be unilaterally revoked by the U.S. Congress, and that U.S. Congress can also withdraw the U.S. citizenship of Puerto Rican residents of Puerto Rico at any time, for a legitimate Federal purpose. The application of the U.S. Constitution to Puerto Rico is limited by the Insular Cases.