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 Ricans in the United States
Since 1898, Puerto Rico has been under the control of the United States, fueling migratory patterns between the mainland and the island. Even during Spanish rule, Puerto Ricans settled in the US. However, it was not until the end of the Spanish–American War in 1898 that a significant influx of Puerto Rican workers to the US began. With its 1898 victory, the United States acquired Puerto Rico from Spain and has retained sovereignty since. The 1917 Jones–Shafroth Act made all Puerto Ricans US citizens, freeing them from immigration barriers. The massive migration of Puerto Ricans to the mainland United States was largest in the early and late 20th century, prior to its resurgence in the early 21st century.