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
Puerto Ricans became citizens of the United States as a result of the passage of the Jones-Shafroth Act of 1917. Since this law was the result of Congressional legislation, and not the result of an amendment to the United States Constitution, the current U.S. citizenship of Puerto Ricans can be revoked by Congress, as they are "statutory citizens", not "14th Amendment citizens". The Jones Act established that Puerto Ricans born prior to 1899 were considered naturalized citizens of Puerto Rico, and anyone born after 1898 were U.S. citizens, unless the Puerto Rican expressed his/her intentions to remain a Spanish subject. Since 1948, it was decided by Congress that all Puerto Ricans, whether born within the United States or in Puerto Rico, were naturally born United States citizens.