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Article

Abstract

For decades, voices both on and off the island of Puerto Rico have decried its status as an "unincorporated territory"-a legal category invented by a fractured U.S. Supreme Court in the widely-reviled Insular Cases a century ago, and technically unchanged by the adoption of a constitution and "commonwealth" status in the 1950s. Broad dissatisfaction with this constitutional and political limbo-neither state nor incorporated territory, "belonging to" but not "part of' the United States,' "foreign

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