Gonzales v. Williams

Background

Isabella Gonzales, an unmarried native and resident of Porto Rico, arrived at the Port of New York on August 24, 1902, and was detained by the immigration commissioner as an "alien immigrant" to be returned if likely to become a public charge. The commissioner relied on an 1891 law that excluded certain "aliens" from admission. Gonzales and her supporters argued she was a citizen of Porto Rico under the treaty ceding the island and the April 12, 1900 act that established civil government for Porto Rico, and so should not be treated as an alien.

Reasoning

The Court addressed the single question whether Gonzales was an "alien" within the meaning of the 1891 immigration statute. Relying on the Treaty of Paris, the act of April 12, 1900, and related departmental opinions and decisions cited in the record, the Court concluded that inhabitants of Porto Rico owed allegiance to the United States and were treated by Congress as citizens of Porto Rico under U.S. authority. Because their nationality and permanent allegiance were to the United States, they were not "aliens" for the purposes of the 1891 law. The immigration commissioner therefore had no power under that statute to detain or deport Gonzales.

Real world impact

The Court reversed the lower court and ordered Gonzales discharged, holding that people who are native inhabitants and citizens of Porto Rico cannot be treated as foreign immigrants under the 1891 law when arriving at United States ports. The decision prevents immigration officers from using that statute to detain or deport Porto Rico citizens arriving by water to the mainland, and it recognizes that Porto Rico residents are subject to U.S. laws and protections rather than exclusion as aliens.