Puerto Rican citizenship
Puerto Rican citizenship was first legislated by the United States Congress in Article 7 of the Foraker Act of 1900 and later recognized in the Constitution of Puerto Rico. Puerto Rican citizenship existed before the U.S. takeover of the islands of Puerto Rico and continued afterwards. Its affirmative standing was also recognized before and after the creation of the Commonwealth of Puerto Rico in 1952. Puerto Rican citizenship was recognized by the United States Congress in the early twentieth century and continues unchanged after the creation of the Commonwealth of Puerto Rico. The United States government also continues to recognize a Puerto Rican nationality. Puerto Rican citizenship was once also recognized by the Spanish Government, which recognized Puerto Ricans as a people with Puerto Rican, and not American citizenship. It also at one time granted Spanish citizenship to Puerto Ricans on the basis of their Puerto Rican (and not American) citizenship.
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.