The political status of Puerto Ricans has been questioned ever since the island was annexed by the United States in the late nineteenth century as a result of the Spanish-American War. Questions regarding the United States citizenship of Puerto Ricans were definitely brought forth during the Supreme Court case Gonzales v. Williams (1904). The case involved Isabel Gonzalez, a twenty-year-old Puerto Rican who decided to leave the island for New York in 1902. Isabel, at the time, was pregnant and planned to reunite with her fiancée who had found a job on the mainland. Isabel also had some relatives residing in New York, including her brother, Luis Gonzalez, and her uncle, Domingo Collazo. Isabel didn’t think any issues would arise from her travels, since it was common for people from the island to travel freely to the United States. However, while on board the S.S Philadelphia, the United States Department of Treasury issued new immigration protocols, ones that would label Isabel as an immigrant alien. Even though Isabel believed herself to be a United States citizen, immigrant officials disallowed her from entering New York. The case was noteworthy and covered extensively by the Puerto Rican press. Newspapers, such as La Correspondencia (1890-1943), worked to question whether Isabel Gonzalez was indeed a United States citizen. Subsequently, her fate came to determine that of the whole Puerto Rican population.
Upon her arrival to the United States, Isabel was detained and transferred to Ellis Island. There, the newly appointed Immigrant Commissioner, William Williams established policies in which individuals traveling with less than ten dollars could be suspect to further investigation. While Isabel did have more than ten dollars on her person, Williams still labeled her with a public charge since she was traveling alone while pregnant. Deemed as “immoral” she was then prevented from entering the mainland until a relative or family member could claim her.
The ordeal turned out to be more complicated as her uncle, Domingo Collazo, and her brother, Luis Gonzalez tried to claim her and convince the officials at Ellis Island that Isabel was not entering the United States for “immoral” reasons. Even with their statements and assurances that they would take care of her, she was not allowed to leave. Thus, Collazo issued a habeas corpus petition for Isabel. The petition was passed through the U.S Circuit Court for the Southern District of New York.
In an issue of La Correspondencia from September 27, 1902, one can find a letter to the Senior Director of the paper from Isabel’s uncle, Domingo Collazo, under the title “Una carta de Nueva York”. A verdict was soon approaching at the circuit court level at the time when the letter was written. Some of the details of the case are related in the letter, such as the names of the judge involved in deciding the verdict, Judge Lacombe, and the lawyers defending Isabel Gonzalez, Charles E. Le Barbier and Orrel A. Parker. Both lawyers were praised by the newspaper as the letter’s subheading exclaims that “Puerto Ricans should give respect and recognition to the American lawyers Charles E. Le Barbier and Parker”. Collazo, in his letter, mentions how he has had to “spend money from his own earnings” for the defense of his niece Isabel Gonzalez. Nonetheless, he believes that something must be done, even “at the expense of the tranquility and the pockets of those who do not care about the elections of the political parties of the island”. Collazo ends his letter with the quote “they want the cage but reject the birds” which relates to the way he feels the United States has treated Puerto Ricans. They want the territory but reject its inhabitants.
At the circuit court level, Judge Lacombe concluded that Isabel Gonzalez was an immigrant alien and could therefore not enter the mainland freely. The facts of the verdict were published on the cover of another issue of La Correspondencia on October 18, 1902.
The case was then appealed to the Supreme Court and American lawyer, Fredric R. Coudert Jr., and Puerto Rican Resident Commissioner Federico Degetau y Gonzalez got involved in the matter. Coudert Jr. had previously been one of the attorneys in another Supreme Court case, Downes v. Bidwell (1901), a case that argued whether the rights from the United States Constitution applied to United States territories. Degetau at the time was extremely active in Puerto Rican politics and advocated for statehood and United States citizenship for the island and its inhabitants. Hence, both figures adamantly fought for Isabel Gonzalez’s cause, even though each had their own approach towards the issue, a fact that scholar Sam Erman outlines well in his article “Meanings of Citizenship in the U.S Empire: Puerto Rico, Isabel Gonzalez, and the Supreme Court.”
A letter from Degetau to the United States Secretary of Commerce and Labor was published in La Correspondencia on October 8, 1903. The letter’s heading declares “Finally, Sir Degetau publically protests the United States immigration laws applied to Puerto Ricans.” In the letter, Degetau expresses issues surrounding United States immigration laws and that deeming Puerto Ricans as alien immigrants went against the Treaty of Paris (1898), the United States Constitution and other United States laws. For example, Degetau evokes the United States March 3, 1903 Act, an act that discusses the regulations of immigrant aliens that come into the United States. Section 2 of the Act lists the types of people excluded in the United States, while Section 33 articulates that the words “United States” encompasses not only the country, but also its territories and the waters surrounding it. Therefore, Degetau cannot understand why residents of the island, such as Isabel Gonzalez, would be deemed as immigrant aliens when in fact Puerto Rico is part of the United States.
The Puerto Rican population were anxious to know the results of the case. This is evident on the front page of the December 19, 1903 edition of La Correspondenica where one can find a subheading stating “Soon we will know the opinion of the United States Supreme Court in regards to our political status. It is discussed with passion in these moments the case of Isabel Gonzalez, that presents the problem of whether ‘the flag follows the Constitution or not’”. In reality, the results of the case didn’t bring much more clarity to the situation. While the case was positive in the sense that it decided that Isabel Gonzalez, and hence all Puerto Ricans, were not immigrant aliens, it left unclear whether they truly were citizens of the United States.
It wasn’t until the Jones Act of 1917, thirteen years after the Isabel Gonzalez case, that Puerto Ricans were officially granted United States citizenship. However, it is important to note that those living on island do not have the same rights as those living in the mainland. One can moreover argue that the political situation in Puerto Rico still remains complicated with many unresolved issues. Therefore, the Isabel Gonzalez Supreme Court case has much relevance today as it is part of a long history of Puerto Ricans and their struggles in attaining their rights.
***Versión en español se encuentra aquí: El caso de Isabel Gonzalez***
Erman, Sam. 2010. Puerto rico and the promise of united states citizenship: Struggles around status in a new empire, 1898-1917. Doctor of Philosophy. University of Michigan.
Erman, Sam. 2008. Meanings of citizenship in the U.S. empire: Puerto rico, isabel gonzalez, and the supreme court, 1898 to 1905. Journal of American Ethnic History(4): 5, http://lp.hscl.ufl.edu/login?url=http://search.ebscohost.com/login.aspx?direct=true&db=edsjsr&AN=edsjsr.27501851&site=eds-live
Smith, Rogers M. 2017. The unresolved constitutional issues of puerto rican citizenship. Centro Journal 29 (1) (Spring2017): 56-75