Territories of the United States

Organized vs. unorganized territories

Former incorporated organized territories of the United States

Definitions

Organized territories are lands under federal sovereignty (but not part of any state or the federal district) that were given a measure of self-governance by Congress through an organic act subject to the Congress's plenary powers under the Territorial Clause of the Constitution's Article Four, section 3. The term unorganized historically had two applications. One application was to a newly acquired region not yet constituted as an organized incorporated territory (e.g. the Louisiana Purchase prior to the establishment of Orleans Territory and the District of Louisiana). The other was to a region that was previously part of an organized incorporated territory, but subsequently left "unorganized" after part of it had been organized and had achieved the requirements for statehood. (E.g., a large portion of Missouri Territory became unorganized territory for several years after its southeastern section became the state of Missouri.)

Historical practice

The Kansas–Nebraska Act of 1854 created the Kansas and Nebraska Territories, bringing organized government to the region once again. The creation of Kansas and Nebraska left the Indian Territory as the only unorganized territory in the Great Plains. In 1858, the western part of the Minnesota Territory became unorganized when it was not included in the new state of Minnesota; this area was organized in 1861 as part of the Dakota Territory. In 1890, the western half of the Indian Territory was organized as Oklahoma Territory. The eastern half remained unorganized until 1907, when it was joined with Oklahoma Territory to form the State of Oklahoma. Additionally, the Department of Alaska was unorganized from its acquisition in 1867 from Russia until organized as the District of Alaska in 1884; it was organized as Alaska Territory in 1912. Hawaii was also unorganized from the time of its annexation by the U.S. in 1898 until organized as Hawaii Territory in 1900.

Regions that have been admitted as states under the United States Constitution in addition to the original thirteen were, most often, prior to admission, territories or parts of territories of this kind. As the United States grew, the most populous parts of the organized territory would achieve statehood. Some territories existed only a short time before becoming states, while others remained territories for decades. The shortest-lived was Alabama Territory at two years, while New Mexico Territory and Hawaii Territory both lasted more than 50 years.

Of the 50 states, 31 were once part of an organized, incorporated U.S. territory. In addition to the original 13, six subsequent states never were: Kentucky, Maine, and West Virginia were each separated from an existing state; Texas and Vermont were both sovereign states (de facto sovereignty for Vermont, as the region was claimed by New York) when they entered the Union; and California was part of unorganized land ceded to the United States by Mexico in 1848 at the end of the Mexican–American War.

Federal administration of current territories

All of the five major U.S. territories are permanently inhabited and have locally elected territorial legislatures and executives and some degree of political autonomy. Four of the five are organized, but American Samoa is technically unorganized. All of the U.S. territories without permanent non-military populations are unorganized.

The Office of Insular Affairs coordinates federal administration of the U.S. territories and freely associated states, except for Puerto Rico.

On March 3, 1849, the last day of the 30th Congress, a bill was passed to create the U.S. Department of the Interior to take charge of the internal affairs of United States territory. The Interior Department has a wide range of responsibilities (which include the regulation of territorial governments, the basic responsibilities for public lands, and other various duties).

In contrast to similarly named Departments in other countries, the United States Department of the Interior is not responsible for local government or for civil administration except in the cases of Indian reservations, through the Bureau of Indian Affairs (BIA), and island dependencies administered by the Office of Insular Affairs. Permanently inhabited territories

Permanently inhabited territories

The U.S. has five permanently inhabited territories: Puerto Rico and the U.S. Virgin Islands in the Caribbean Sea, Guam and the Northern Mariana Islands in the North Pacific Ocean, and American Samoa in the South Pacific Ocean. American Samoa is in the Southern Hemisphere, while the other four are in the Northern Hemisphere. In 2020, their combined population was about 3.62 million, over 90% of which is accounted for by Puerto Rico alone.

People born in Puerto Rico, the U.S. Virgin Islands, Guam and the Northern Mariana Islands acquire U.S. citizenship by birth, and foreign nationals residing there may apply for U.S. citizenship by naturalization. People born in American Samoa acquire U.S. nationality but not U.S. citizenship by birth if they do not have a U.S. citizen parent, as the American Samoan people have consistently refused birthright citizenship, fearing this would undermine indigenous land ownership, governance, and culture.{{Cite Journal |title=Birthright Citizenship for American Samoans Tradition versus Nationalism?

Each territory is self-governing with three branches of government, including a locally elected governor and a territorial legislature. Each territory elects a non-voting member (a non-voting resident commissioner in the case of Puerto Rico) to the U.S. House of Representatives. Although they cannot vote on the passage of legislation, they can introduce legislation, have floor privileges to address the house, be members of and vote in committees, are assigned offices and staff funding, and may nominate constituents from their territories to the Army, Naval, Air Force and Merchant Marine academies.

As of the 119th Congress, the territories are represented by Uifa’atali Aumua Amata Radewagen (R) of American Samoa, James Moylan (R) of Guam, Kimberlyn King-Hinds (R) of Northern Mariana Islands, Pablo Hernández Rivera (D-PPD) of Puerto Rico and Stacey Plaskett (D) of U.S. Virgin Islands. The District of Columbia's delegate is Eleanor Holmes Norton (D); like the district, the territories have no vote in Congress and no representation in the Senate. Additionally, the Cherokee Nation has delegate-elect Kimberly Teehee, who has not been seated by Congress.

Every four years, U.S. political parties nominate presidential candidates at conventions which include delegates from the territories. U.S. citizens living in the territories can vote for presidential candidates in these primary elections but not in the general election.

The territorial capitals are Pago Pago (American Samoa), Hagåtña (Guam), Saipan (Northern Mariana Islands), San Juan (Puerto Rico) and Charlotte Amalie (U.S. Virgin Islands). Their governors are Pula Nikolao Pula (American Samoa), Lou Leon Guerrero (Guam), David M. Apatang (Northern Mariana Islands), Jenniffer González-Colón (Puerto Rico) and Albert Bryan Jr. (U.S. Virgin Islands).

Among the inhabited territories, Supplemental Security Income (SSI) is available only in the Northern Mariana Islands; however, in 2019 a U.S. judge ruled that the federal government's denial of SSI benefits to residents of Puerto Rico is unconstitutional. This ruling was later overturned by the U.S. Supreme Court, allowing for the exclusion of territories from such programs. In the decision, the court explained that the exemption of island residents from most federal income taxes provides a "rational basis" for their exclusion from eligibility for SSI payments.

American Samoa is the only U.S. territory with its own immigration system (a system separate from the United States immigration system). American Samoa also has a communal land system in which 90% of the land is communally owned; ownership is based on the Samoan system of governance, in which a political entity called a matai own land communally and administers it on behalf of the polity or nu'u.

History

History

• American Samoa: territory since 1900; after the end of the Second Samoan Civil War, the Samoan Islands were divided into two regions. The U.S. took control of the eastern half of the islands. In 1900, the Treaty of Cession of Tutuila took effect. The Manuʻa Islands became part of American Samoa in 1904, and Swains Island became part of American Samoa in 1925. Congress ratified American Samoa's treaties in 1929. For 51 years, the U.S. Navy controlled the territory. American Samoa is locally self-governing under a constitution last revised in 1967. The first elected governor of American Samoa was in 1977, and the first non-voting member of Congress was in 1981. By jus soli, people born in American Samoa are U.S. nationals, but not U.S. citizens. American Samoa is technically unorganized, and its main island is Tutuila.
• Guam: territory since 1899, acquired at the end of the Spanish–American War. Guam is the home of Naval Base Guam and Andersen Air Force Base. It was organized under the Guam Organic Act of 1950, which granted U.S. citizenship to Guamanians and gave Guam a local government. In 1968, the act was amended to permit the election of a governor.
• Northern Mariana Islands: A commonwealth since 1986, the Northern Mariana Islands together with Guam were part of the Spanish Empire until 1899 when the Northern Marianas were sold to the German Empire after the Spanish–American War. Beginning in 1919, they were administered by Japan as a League of Nations mandate until the islands were captured by the United States in the Battle of Saipan and Battle of Tinian (June–August 1944) and the surrender of Aguiguan (September 1945) during World War II. They became part of the United Nations Trust Territory of the Pacific Islands (TTPI) in 1947, administered by the United States as U.N. trustee. The other constituents of the TTPI were Palau, the Federated States of Micronesia and the Marshall Islands. Following failed efforts in the 1950s and 1960s to reunify Guam and the Northern Marianas, a covenant to establish the Northern Mariana Islands as a commonwealth in political union with the United States was negotiated by representatives of both political bodies; it was approved by Northern Mariana Islands voters in 1975, and came into force on March 24, 1976. In accordance with the covenant, the Northern Mariana Islands constitution partially took effect on January 9, 1978, and became fully effective on November 4, 1986. In 1986, the Northern Mariana Islands formally left U.N. trusteeship. The abbreviations "CNMI" and "NMI" are both used in the commonwealth. Most residents in the Northern Mariana Islands live on Saipan, the main island.
• Puerto Rico: unincorporated territory since 1899; Puerto Rico was acquired at the end of the Spanish–American War, and has been a U.S. commonwealth since 1952. Since 1917, Puerto Ricans have been granted U.S. citizenship. Puerto Rico was organized under the Puerto Rico Federal Relations Act of 1950 (Public Law 600). In November 2008, a U.S. District Court judge ruled that a series of Congressional actions have had the cumulative effect of changing Puerto Rico's status from unincorporated to incorporated. The issue is proceeding through the courts, however, and the U.S. government still refers to Puerto Rico as unincorporated. A Puerto Rican attorney has called the island "semi-sovereign". Puerto Rico has a statehood movement, whose goal is to make the territory the 51st state. See also Political status of Puerto Rico.
• U.S. Virgin Islands: purchased by the U.S. from Denmark in 1917 and organized under the Revised Organic Act of the Virgin Islands in 1954. U.S. citizenship was granted in 1927. The main islands are Saint Thomas, Saint John and Saint Croix.

Statistics

Except for Guam, the inhabited territories lost population in 2020. Although the territories have higher poverty rates than the mainland U.S., they have high Human Development Indexes. Four of the five territories have another official language, in addition to English.

The territories do not have administrative counties. The U.S. Census Bureau counts Puerto Rico's 78 municipalities, the U.S. Virgin Islands' three main islands, all of Guam, the Northern Mariana Islands' four municipalities, and American Samoa's three districts and two atolls as county equivalents. The Census Bureau also counts each of the U.S. Minor Outlying Islands as county equivalents.

For statistical purposes, the U.S. Census Bureau has a defined area called the "Island Areas" which consists of American Samoa, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands (every major territory except Puerto Rico). The U.S. Census Bureau often treats Puerto Rico as its own entity or groups it with the states and D.C. (for example, Puerto Rico has a QuickFacts page just like the states and D.C.) Puerto Rico data is collected annually in American Community Survey estimates (just like the states), but data for the other territories is collected only once every ten years.

Governments and legislatures

The five major inhabited territories contain the following governments and legislatures:

Political party status

The following is the political party status of the governments of the U.S. territories following completion of the 2024 United States elections. Instances where local and national party affiliation differs, the national affiliation is listed second. Guam and the U.S. Virgin Islands have unicameral territorial legislatures.

Courts

Each of the five major territories has its own local court system:

• High Court of American Samoa
• Supreme Court of Guam
• Supreme Court of the Northern Mariana Islands
• Supreme Court of Puerto Rico
• Supreme Court of the Virgin Islands

Of the five major territories, only Puerto Rico has an Article III federal district court (i.e., equivalent to the courts in the fifty states); it became an Article III court in 1966. This means that, unlike other U.S. territories, federal judges in Puerto Rico have life tenure. Federal courts in Guam, the Northern Mariana Islands and the U.S. Virgin Islands are Article IV territorial courts. The following is a list of federal territorial courts, plus Puerto Rico's court:

• District Court of Guam (Ninth Circuit)
• District Court for the Northern Mariana Islands (Ninth Circuit)
• District Court for the District of Puerto Rico (not a territorial court) (First Circuit)
• District Court of the Virgin Islands (Third Circuit)

American Samoa does not have a federal territorial court, and so federal matters in American Samoa are sent to either the District court of Hawaii or the District court of the District of Columbia. American Samoa is the only permanently inhabited region of the United States with no federal court.

Demographics

While the U.S. mainland is majority non-Hispanic White, this is not the case for the U.S. territories. In 2010, American Samoa's population was 92.6% Pacific Islander (including 88.9% Samoan); Guam's population was 49.3% Pacific Islander (including 37.3% Chamorro) and 32.2% Asian (including 26.3% Filipino); the population of the Northern Mariana Islands was 34.9% Pacific Islander and 49.9% Asian; and the population of the U.S. Virgin Islands was 76.0% African American. In 2019, Puerto Rico's population was 98.9% Hispanic or Latino, 67.4% white, and 0.8% non-Hispanic white.

Throughout the 2010s, the U.S. territories (overall) lost population. The combined population of the five inhabited territories was 4,100,594 in 2010, and 3,569,284 in 2020.

The U.S. territories have high religiosity rates—American Samoa has the highest religiosity rate in the United States (99.3% religious and 98.3% Christian).

Economies

The economies of the U.S. territories vary from Puerto Rico, which has a GDP of $104.989 billion in 2019, to American Samoa, which has a GDP of $636 million in 2018. In 2018, Puerto Rico exported about $18 billion in goods, with the Netherlands as the largest destination.

Guam's GDP shrank by 0.3% in 2018, the GDP of the Northern Mariana Islands shrank by 19.6% in 2018, Puerto Rico's GDP grew by 1.18% in 2019, and the U.S. Virgin Islands' GDP grew by 1.5% in 2018. In 2017, American Samoa's GDP shrank by 5.8%, but then grew by 2.2% in 2018.

American Samoa has the lowest per capita income in the United States—it has a per capita income comparable to that of Botswana. In 2010, American Samoa's per capita income was $6,311. As of 2010, the Manuʻa District in American Samoa had a per capita income of $5,441, the lowest of any county or county-equivalent in the United States. In 2018, Puerto Rico had a median household income of $20,166 (lower than the median household income of any state). Also in 2018, Comerío Municipality, Puerto Rico had a median household income of $12,812 (the lowest median household income of any populated county or county-equivalent in the U.S.) Guam has much higher incomes (Guam had a median household income of $48,274 in 2010.) Uninhabited territories

Minor Outlying Islands

Main article: United States Minor Outlying Islands

The United States Minor Outlying Islands are small uninhabited islands, atolls, and reefs. Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Atoll, Palmyra Atoll, and Wake Island are in the Pacific Ocean while Navassa Island is in the Caribbean Sea. The additional claimed territories of Bajo Nuevo Bank and Serranilla Bank are also located in the Caribbean Sea. Palmyra Atoll (formally known as the United States Territory of Palmyra Island) is the only incorporated territory, a status it has maintained since Hawaii became a state in 1959. All are uninhabited except for Midway Atoll, whose approximately 40 inhabitants (as of 2004) were employees of the U.S. Fish and Wildlife Service and their services provider; Palmyra Atoll, whose population varies from four to 20 Nature Conservancy and Fish and Wildlife staff and researchers; and Wake Island, which has a population of about 100 military personnel and civilian employees. The two-letter abbreviation for the islands collectively is "UM".

The status of several islands is disputed. Navassa Island is disputed by Haiti, Wake Island is disputed by the Marshall Islands, Swains Island (a part of American Samoa) is disputed by Tokelau, and Bajo Nuevo Bank and Serranilla Bank are both administered by Colombia, whose claim is disputed by the U.S.

Claimed territories

The following two territories are claimed by multiple countries (including the United States) and are not included in ISO 3166-2:UM. However, they are sometimes grouped with the U.S. Minor Outlying Islands. According to the GAO, "the United States conducts maritime law enforcement operations in and around Serranilla Bank and Bajo Nuevo [Bank] consistent with U.S. sovereignty claims."

Incorporated vs. unincorporated territories

Pursuant to a series of Supreme Court rulings, Congress decides whether a U.S. territory is incorporated or unincorporated. The U.S. Constitution applies to each incorporated territory (including its local government and inhabitants) as it applies to the local governments and residents of a state. The sole incorporated territory (also known as a Territory, distinct from territory) of the U.S., Palmyra Atoll, is an insular part of the U.S. (neither a part of one of the several States nor a Federal district), but is not a possession.

In unincorporated territories, "fundamental rights apply as a matter of law, but other constitutional rights are not available", raising concerns about how the population in these territories can take part in the political process. Selected constitutional provisions apply, depending on congressional acts and judicial rulings according to U.S. constitutional practice, local tradition, and law. As a result, these territories are often considered colonies of the United States.

The judicial term "unincorporated" was coined to legitimize the late-19th-century territorial acquisitions without citizenship and their administration without constitutional protections temporarily until Congress made other provisions. The case law allowed Congress to impose discriminatory tax regimes with the effect of a protective tariff upon territorial regions which were not domestic states. In 2022, the United States Supreme Court in United States v. Vaello Madero held that the territorial clause of the constitution allowed wide congressional latitude in mandating "reasonable" tax and benefit schemes in Puerto Rico and the other territories, which are different from the states, but did not address the incorporated/unincorporated distinction. In a concurrence with the court's overall ruling on the propriety of the differential tax structures, one of the justices opined that it was time to overrule the doctrine of unincorporated territories, as wrongly decided and founded in racism; the dissent agreed with this view.

Insular Cases

Main article: Insular Cases

The U.S. Supreme Court, in its 1901–1905 Insular Cases opinions, ruled that the Constitution extended ex proprio vigore (i.e., of its own force) to the continental territories. The Court also established the doctrine of territorial incorporation, in which the Constitution applies fully to incorporated territories (such as the then-territories of Alaska and Hawaii) and partially in the unincorporated territories of Guam, Puerto Rico, and, at the time, the Philippines (which is no longer a U.S. territory).

In the 1901 Supreme Court case Downes v. Bidwell, the Court said that the U.S. Constitution did not fully apply in unincorporated territories because they were inhabited by "alien races".

The U.S. had no unincorporated territories (also known as overseas possessions or insular areas) until 1856. Congress enacted the Guano Islands Act that year, authorizing the president to take possession of unclaimed islands to mine guano. The U.S. has taken control of (and claimed rights on) many islands and atolls, especially in the Caribbean Sea and the Pacific Ocean, under this law; most have been abandoned. It also has acquired territories since 1856 under other circumstances, such as under the Treaty of Paris (1898) which ended the Spanish–American War. The Supreme Court considered the constitutional position of these unincorporated territories in 1922 in Balzac v. People of Porto Rico, and said the following about a U.S. court in Puerto Rico:

In Glidden Company v. Zdanok, the Court cited Balzac and said about courts in unincorporated territories: "Upon like considerations, Article III has been viewed as inapplicable to courts created in unincorporated territories outside the mainland... and to the consular courts established by concessions from foreign countries". The judiciary determined that incorporation involves express declaration or an implication strong enough to exclude any other view, raising questions about Puerto Rico's status.

In 1966, Congress made the United States District Court for the District of Puerto Rico an Article III district court. This (the only district court in a U.S. territory) sets Puerto Rico apart judicially from the other unincorporated territories, and U.S. district judge Gustavo Gelpí has expressed the opinion that Puerto Rico is no longer unincorporated:

In Balzac, the Court defined "implied":

On June 5, 2015, the U.S. Court of Appeals for the District of Columbia ruled 3–0 in Tuaua v. United States to deny birthright citizenship to American Samoans, ruling that the guarantee of such citizenship to citizens in the Fourteenth Amendment does not apply to unincorporated U.S. territories. In 2016 the U.S. Supreme Court declined to review the appellate court's decision.

In 2018, the United States Court of Appeals for the 7th Circuit upheld the District Court decision in Segovia v. United States, which ruled that former Illinois residents living in Puerto Rico, Guam, and the U.S. Virgin Islands did not qualify to cast overseas ballots according to their last registered address on the U.S. mainland. (Residents of the Northern Marianas and American Samoa, however, were still allowed to cast such ballots.) In October 2018, the U.S. Supreme Court declined to review the 7th Circuit's decision.

On June 15, 2021, the United States Court of Appeals for the Tenth Circuit ruled 2–1 in Fitisemanu v. United States to deny birthright citizenship to American Samoans and not to overrule the Insular Cases. The court cited Downes and ruled that "neither constitutional text nor Supreme Court precedent" demands that American Samoans should be given automatic birthright citizenship. The case was denied certiorari by the U.S. Supreme Court. On April 21, 2022, in the case United States v. Vaello Madero, Justice Gorsuch urged the Supreme Court to overrule the Insular Cases when possible as they "rest on a rotten foundation" and called the cases "shameful".

In analyzing the Insular Cases, Christina Duffy Ponsa (Juris Doctor, Yale Law School, 1998; former law clerk for Justice Stephen Breyer) wrote in The New York Times: "To be an unincorporated territory is to be caught in limbo: although unquestionably subject to American sovereignty, they are considered part of the United States for certain purposes but not others. Whether they are part of the United States for purposes of the Citizenship Clause remains unresolved."

U.S. Supreme Court decisions about particular territories

Supreme Court decisions about current territories

The 2016 Supreme Court case Puerto Rico v. Sanchez Valle ruled that territories do not have their own sovereignty. That year, the Supreme Court declined to rule on a lower-court ruling in Tuaua v. United States that American Samoans are not U.S. citizens at birth.

The Supreme Court ruled in 2022 in United States v. Vaello-Madero that Congress is not required to extend all benefits to Puerto Ricans, and that the exclusion of Puerto Ricans from the Supplemental Security Income program was constitutional.

Supreme Court decisions about former territories

In Rassmussen v. U.S., the Supreme Court quoted from Article III of the 1867 treaty for the purchase of Alaska:

The act of incorporation affects the people of the territory more than the territory itself by extending the Privileges and Immunities Clause of the Constitution to them, such as its extension to Puerto Rico in 1947; however, Puerto Rico remains unincorporated.

Alaska Territory

Rassmussen arose from a criminal conviction by a six-person jury in Alaska under federal law. The court held that Alaska had been incorporated into the U.S. in the treaty of cession with Russia, and the congressional implication was strong enough to exclude any other view:

Concurring justice Henry Brown agreed:

Florida Territory

In Dorr v. U.S., the court quoted Chief Justice John Marshall from an earlier case:

In Downes v. Bidwell, the court said: "The same construction was adhered to in the treaty with Spain for the purchase of Florida... the 6th article of which provided that the inhabitants should 'be incorporated into the Union of the United States, as soon as may be consistent with the principles of the Federal Constitution'."

Southwest Territory

Justice Brown first mentioned incorporation in Downes:

Louisiana Territory

In Downes, the court said:

Puerto Rico

Scholars agreed as of 2009 in the Boston College Law Review, "Regardless of how Puerto Rico looked in 1901 when the Insular Cases were decided, or in 1922, today, Puerto Rico seems to be the paradigm of an incorporated territory as modern jurisprudence understands that legal term of art". In November 2008, a district court judge ruled that a sequence of prior Congressional actions had the cumulative effect of changing Puerto Rico's status to incorporated. However, in 2022, the United States Supreme Court held that the territorial clause of the U.S. constitution allows wide congressional latitude in mandating "reasonable" tax and benefit schemes in Puerto Rico and the other territories that are different from the states, but the Court did not address the incorporated/unincorporated distinction. As a result, the status quo remains, so the U.S. government still defines the Commonwealth of Puerto Rico as a U.S. unincorporated territory.

Former unincorporated territories and administered areas

{anchor Areas formerly administered by the United States

Former unincorporated territories

• Swan Islands (1863–1972): claimed under the Guano Islands Act; sovereignty ceded to Honduras in a 1972 treaty.
• Republic of Hawaii (1898–1900): became the Territory of Hawaii after it was organized and incorporated by the Hawaiian Organic Act on April 30, 1900.
• Philippines: military government, 1898-1902 (in conflict with Revolutionary Government of the Philippines and later First Philippine Republic); insular government, 1901–1935; commonwealth government, 1935–1942 and 1945–1946 (islands under Japanese occupation, 1942–1945 and puppet state, 1943–1945); granted independence on July 4, 1946, by the Treaty of Manila.

Former U.S.-administered areas

• Panama Canal (1903–1999): Canal Zone abolished on October 1, 1979, after the signing of the Torrijos–Carter Treaties in 1977. The U.S. retained a military base on the former Canal Zone until December 31, 1999, when joint U.S.-Panama control of the Panama Canal ended.
• Corn Islands (1914–1971): leased for 99 years under the Bryan–Chamorro Treaty, but returned to Nicaragua after the treaty was annulled in 1970.
• Canton and Enderbury Islands (1939–1979): condominium jointly administered by the United States and the United Kingdom.
• Trust Territory of the Pacific Islands (1947–1994): U.N. trust territory administered by the U.S.; included the Marshall Islands, the Federated States of Micronesia, and Palau, which are sovereign states (that have entered into a Compact of Free Association with the U.S.), along with the Commonwealth of the Northern Mariana Islands.
• Nanpō Islands and Marcus Island (1952–1968): returned to Japan by mutual agreement.
• Ryukyu Islands and Daitō Islands (1952–1972): returned to Japan in an agreement.

Former U.S. military occupations

• First occupation of Cuba (1898–1902): sovereignty over the island relinquished by Spain on April 11, 1899, when the Treaty of Paris took effect. Cuban independence was recognized on May 20, 1902.
• Military occupation of the Philippines, Puerto Rico, and Guam during the Spanish–American War (1898–1899): territories annexed on April 11, 1899, when the Treaty of Paris took effect.
• Second occupation of Cuba (1906–1909)
• United States occupation of Nicaragua (1912–1933)
• United States occupation of Veracruz (1914)
• United States occupation of Haiti (1915–1934)
• United States occupation of the Dominican Republic (1916–1924)
• Sugar Intervention in Cuba (1917–1922)
• Participation in the Occupation of Austria-Hungary (1918–1919)
• Participation in the Occupation of the Rhineland (1918–1921)
• Participation in the Occupation of Constantinople (1918–1923)
• Occupation of Greenland in World War II (1941–1945)
• Occupation of Iceland in World War II (1941–1946): military base retained until 2006.
• Allied Military Government for Occupied Territories, in Allied-controlled sections of Italy from the July 1943 invasion of Sicily until the September armistice with Italy. AMGOT continued in newly liberated areas of Italy until the end of the war, and also existed in France.
• Occupation of Clipperton Island in World War II (1944–1945): occupied territory, returned to France on October 23, 1945.
• United States Army Military Government in Korea: occupation south of the 38th parallel from 1945 to 1948.
• American zones of Allied-occupied Germany (1945–1949)
• Occupation of Japan (1945–1952)
• Nanpō Islands and Marcus Island (1945–1952)
• Ryukyu Islands and Daitō Islands (1945–1952)
• American occupation zones in Allied-occupied Austria and Vienna (1945–1955)
• American occupation zone in West Berlin (1945–1990)
• Free Territory of Trieste (1947–1954): the U.S. co-administered a portion of the territory (between the Kingdom of Italy and the former Kingdom of Yugoslavia) with the United Kingdom.
• Operation Power Pack, Dominican Republic (1965–66)
• Grenada invasion and occupation (1983)
• Panama invasion and occupation (1989–1990)
• Operation Uphold Democracy, Haiti (1994–1995)
• Coalition Provisional Authority, Iraq (2003–2004)
• Green Zone, Iraq (March 20, 2003December 31, 2008){{Citation |access-date=February 25, 2017 |archive-date=July 22, 2016 |archive-url=https://web.archive.org/web/20160722204057/http://www.nytimes.com/2009/01/01/world/middleeast/01greenzone.html?_r=1&ref=todayspaper |url-status=live

Flora and fauna

Flora and fauna

The territories of the United States have many plant and animal species found nowhere else in the United States. All U.S. territories have tropical climates and ecosystems.

Forests

The USDA says the following about the U.S. territories (plus Hawaii):

Forests in the U.S. territories are vulnerable to invasive species and new housing developments. El Yunque National Forest in Puerto Rico is the only tropical rain forest in the United States National Forest system.

American Samoa has 80.84% forest cover and the Northern Mariana Islands has 80.37% forest cover—these are among the highest forest cover percentages in the United States (only Maine and New Hampshire are higher).

Birds

U.S. territories have many bird species that are endemic (not found in any other location).

Introduction of the invasive brown tree snake has harmed Guam's native bird population—nine of twelve endemic species have become extinct, and the territorial bird (the Guam rail) is extinct in the wild.

Puerto Rico has several endemic bird species, such as the critically endangered Puerto Rican parrot, the Puerto Rican flycatcher, and the Puerto Rican spindalis. The Northern Mariana Islands has the Mariana swiftlet, Mariana crow, Tinian monarch and golden white-eye (all endemic). Birds found in American Samoa include the many-colored fruit dove, the blue-crowned lorikeet, and the Samoan starling.

The Wake Island rail (now extinct) was endemic to Wake Island, and the Laysan duck is endemic to Midway Atoll and the Northwest Hawaiian Islands. Palmyra Atoll has the second-largest red-footed booby colony in the world, and Midway Atoll has the largest breeding colony of Laysan albatross in the world.

The American Birding Association currently excludes the U.S. territories from their "ABA Area" checklist.

Other animals

American Samoa has several reptile species, such as the Pacific boa (on the island of Ta‘ū) and Pacific slender-toed gecko. American Samoa has only a few mammal species, such as the Pacific (Polynesian) sheath-tailed bat, as well as oceanic mammals such as the Humpback whale. Guam and the Northern Mariana Islands also have a small number of mammals, such as the Mariana fruit bat; oceanic mammals include Fraser's dolphin and the Sperm whale. The fauna of Puerto Rico includes the common coquí (frog), while the fauna of the U.S. Virgin Islands includes species found in Virgin Islands National Park (including 302 species of fish).

American Samoa has a location called Turtle and Shark which is important in Samoan culture and mythology. Cultural image

Protected areas

There are two National Parks in the U.S. territories: the National Park of American Samoa, and Virgin Islands National Park. The National Park Service also manages War in the Pacific National Historical Park on Guam. There are also National Natural Landmarks, National Wildlife Refuges (such as Guam National Wildlife Refuge), El Yunque National Forest in Puerto Rico, and the Pacific Islands Heritage Marine National Monument (which includes the U.S. Minor Outlying Islands).

Public image

The United Nations list of non-self-governing territories maintained by the Special Committee on Decolonization includes three US territories: American Samoa, Guam, and the United States Virgin Islands. Puerto Rico was removed from the list in 1952 when it became a Commonwealth. The Northern Mariana Islands were removed in 1990, after United Nations Security Council Resolution 683 recognized NMI's 1986 status change to Commonwealth.

In The Not-Quite States of America, his book about the U.S. territories, essayist Doug Mack said:

Representative Stephanie Murphy of Florida said about a 2018 bill to make Puerto Rico the 51st state, "The hard truth is that Puerto Rico's lack of political power allows Washington to treat Puerto Rico like an afterthought." According to Governor of Puerto Rico Ricardo Rosselló, "Because we don't have political power, because we don't have representatives, [no] senators, no vote for president, we are treated as an afterthought." Rosselló called Puerto Rico the "oldest, most populous colony in the world".

Rosselló and others have referred to the U.S. territories as American "colonies". David Vine of The Washington Post said the following: "The people of [the U.S. territories] are all too accustomed to being forgotten except in times of crisis. But being forgotten is not the worst of their problems. They are trapped in a state of third-class citizenship, unable to access full democratic rights because politicians have long favored the military's freedom of operation over protecting the freedoms of certain U.S. citizens." In his article "How the U.S. Has Hidden Its Empire", Daniel Immerwahr of The Guardian writes, "The confusion and shoulder-shrugging indifference that mainlanders displayed [toward territories] at the time of Pearl Harbor hasn't changed much at all. [...] [Maps of the contiguous U.S.] give [mainlanders] a truncated view of their own history, one that excludes part of their country." The 2020 U.S. census excludes non-citizen U.S. nationals in American Samoa—in response to this, Mark Joseph Stern of Slate said, "The Census Bureau's total exclusion of American Samoans provides a pertinent reminder that, until the courts step in, the federal government will continue to treat these Americans with startling indifference."

Galleries

Current territorial non-voting members of the House of Representatives

Members of the House of Representatives (non-voting)

File:Aumua Amata Radewagen congressional photo.jpg|alt=Official photo, with American flag|Amata Coleman Radewagen (R), (American Samoa) File:James Moylan official photo (1).jpg|alt=Official photo|James Moylan (R), (Guam) File:Kimberlyn King-Hinds official portrait.jpg|alt=Official photo|Kimberlyn King-Hinds (R), (Northern Mariana Islands) File:Hernández Rivera Pablo 119th Congress.jpg|alt=Official photo|Pablo Hernández Rivera (D), (Puerto Rico) File:Rep._Stacey_E.Plaskett(VI).jpg|alt=Official photo|Stacey Plaskett (D), (U.S. Virgin Islands) Current territorial governors

Territorial governors

File:Nikolao Pula with CHCC Staff 2022-04-09 Cropped.jpg|alt=Pula Nikolao Pula|Pula Nikolao Pula (R), (American Samoa) File:Lou Leon Guerrero in 2018.jpeg|alt=Lou Leon Guerrero|Lou Leon Guerrero (D), (Guam) File:David Apatang Standing with USAF Airmen Cropped.jpg|alt=Arnold Palacios|David M. Apatang (I), (Northern Mariana Islands) File:Official portrait of Resident Commissioner Jenniffer Gonzalez (4x5 cropped).jpg|alt=Jenniffer González-Colón|Jenniffer González-Colón (PNP-R), (Puerto Rico) File:Governor_Albert_Bryan_Jr..jpg|alt=Albert Bryan|Albert Bryan Jr. (D), (U.S. Virgin Islands)

Satellite images

File:TutuilaFromSpace.jpg|Tutuila and Aunu'u (American Samoa) File:Guam ali 2011364 lrg.jpg|Guam File:Saipan from ISS 2.png|Saipan (Northern Mariana Islands) File:STS034-76-88.jpg|Puerto Rico File:US Virgin Islands.png|U.S. Virgin Islands Uninhabited territories (U.S. Minor Outlying Islands)

File:BakerIsland_ISS010.jpg|alt=Satellite photo|Baker Island File:Howland_island_nasa.jpg|alt=Satellite photo|Howland Island File:JarvisISS008-E-14052.PNG|alt=Satellite photo|Jarvis Island File:Johnston_Atoll.png|alt=Satellite photo|Johnston Atoll File:Kingman_Reef_-2014-02-18-Landsat_8-_15m.png|alt=Satellite photo|Kingman Reef File:Midway_Atoll_aerial_photo_2008.JPG|alt=Satellite photo|Midway Atoll File:Navassa_ISS014.jpg|alt=Satellite photo|Navassa Island File:Palmyra_Atoll_2010-03-18,_EO-1_ALI_bands_5-4-3-1,_15m_resolution.png|alt=Satellite photo|Palmyra Atoll File:Wake_Island.png|alt=Satellite photo|Wake Island

Maps

File:Aq-map.png|American Samoa File:Guam - Location Map (2013) - GUM - UNOCHA.svg|Guam File:Northern Mariana Islands map.gif|Northern Mariana Islands File:Rico (1).png|Puerto Rico File:Virgin Islands-CIA WFB Map.png|U.S. Virgin Islands File:NOAA Map of the US EEZ.svg|U.S. exclusive economic zone

Notes

References

References

1. "Definition of Terms—1120 Acquisition of U.S. Nationality in U.S. Territories and Possessions". U.S. Department of State.
2. (n.d.). "Puerto Rico v. Sanchez Valle". [[Oyez Project]].
3. (June 9, 2016). "Puerto Rico not sovereign, Supreme Court says".
4. (June 12, 2015). "Definitions of Insular Area Political Organizations". U.S. Department of the Interior.
5. "Renewable Resource Management for U.S. Insular Areas—Integrated".
6. "What Are The US Territories?".
7. (April 10, 2017). "Introduction – Harvard Law Review".
8. Perez, Lisa Marie. (June 2008). "Citizenship Denied: The 'Insular Cases' and the Fourteenth Amendment". Virginia Law Review.
9. Memea Kruse, Line-Noue. (2018). "The Pacific Insular Case of American Sāmoa".
10. (November 1997). "U.S. Insular Areas. Application of the U.S. Constitution". United States General Accounting Office.
11. (March 23, 2007). "Unresolved Maritime Boundary Problems in the Caribbean". Harte Research Institute for Gulf of Mexico Studies.
12. (October 2012). "Bajo Nuevo Bank (Petrel Islands) and Serranilla Bank".
13. (2012). "United States Summary, 2010: Population and housing unit counts". U.S. Department of Commerce, Economics and Statistics Administration, [[United States Census Bureau.
14. Smith, Gary Alden. (February 28, 2011). "State and National Boundaries of the United States". McFarland.
15. (March 12, 2020). "The last time Congress created a new state". National Constitution Center.
16. "The most expensive internet in America: fighting to bring affordable broadband to American Samoa". Engadget.
17. (March 2, 2017). "American Samoa Governor Says Small Economies 'Cannot Afford Any Reduction In Medicaid' {{!}} Pacific Islands Report". www.pireport.org.
18. "Poverty Determination in U.S. Insular Areas".
19. "Non-Self-Governing Territories {{!}} The United Nations and Decolonization".
20. Leibowitz, Arnold H.. (1989-01-01). "Defining Status". Brill {{!}} Nijhoff.
21. Uiagalelei, Talaimalo. (2013). "South Pacific Land Systems". University of the South Pacific.
22. "Secure Request and Redirect".
23. (2025-04-17). "Health-Related Quality of Life in the US Territories of Puerto Rico, Guam, and the Virgin Islands". JAMA Network Open.
24. "World Bank Open Data".
25. (May 2015). "Insights in public health: a tale of two polities: health in Independent and American Samoa". Hawai'i Journal of Medicine & Public Health: A Journal of Asia Pacific Medicine & Public Health.
26. U.S. Const. art. IV, § 3, cl. 2 ("The Congress shall have Power to dispose of and make all needful Rules and Regulations respecting the Territory or other Property belonging to the United States{{nbsp...").
27. Riccards, Michael P.. (1997). "Lincoln and the Political Question: The Creation of the State of West Virginia". Presidential Studies Quarterly.
28. (June 11, 2015). "Puerto Rico".
29. "Table A. Apportionment Population, Resident Population, and Overseas Population: 2020 Census and 2010 Census". U.S. Census Bureau.
30. "2020 Population of U.S. Island Areas Just Under 339,000". U.S. Census Bureau.
31. (April 8, 2018). "Am Samoans aren't actually citizens". Samoa News.
32. Pampuro, Amanda. (June 16, 2021). "American Samoans Are Not Born Into US Citizenship". Courthouse News Service.
33. "State Department Foreign Affairs Manual (FAM)".
34. Keating, Joshua. (June 15, 2015). "How Come American Samoans Still Don't Have U.S. Citizenship at Birth?". Slate.
35. Simmons, Ann M.. (April 6, 2018). "American Samoans Aren't Actually U.S. Citizens: Does That Violate The Constitution?". Los Angeles Times.
36. Brady, Heather. (March 30, 2018). "Why Are American Samoans Not U.S. Citizens?". National Geographic.
37. "A Guide to Naturalization". U.S. Citizenship and Immigration Services.
38. (July 23, 2018). "Op-ed: "Lamentations of a third-class American Samoan citizen". Samoa News.
39. (December 30, 2011). "Common Core Document of the United States of America". U.S. Department of State.
40. "The United Nations and Decolonization". United Nations.
41. "The House Explained". U.S. House of Representatives.
42. "United States House of Representatives Directory".
43. (September 19, 2018). "Puerto Rico governor asks Trump to consider statehood".
44. "2016 Presidential Primaries, Caucuses, and Conventions Alphabetically by State". Green Papers.
45. (March 9, 2015). "Watch John Oliver Cast His Ballot for Voting Rights for U.S. Territories".
46. (2017). "The Not-Quite States of America: Dispatches from the Territories and Other Far-Flung Outposts of the USA". W. W. Norton & Company.
47. Coto, Danica. (February 4, 2019). "Judge's Ruling Pushes Puerto Rico to Pursue SSI Benefits". StarTribune.
48. Hurley, Lawrence. (April 21, 2022). "U.S. Supreme Court allows Puerto Rico's exclusion from welfare program". Reuters.
49. (April 21, 2022). "High Court upholds excluding Puerto Ricans from aid for disabled and blind". [[NPR]].
50. (June 11, 2015). "American Samoa". U.S. Department of the Interior.
51. "Immigration Office".
52. "American Samoa". Department of the Interior – American Samoa.
53. Reagan, Ronald. (November 3, 1986). "Placing Into Full Force and Effect the Covenant With the Commonwealth of the Northern Mariana Islands, and the Compacts of Free Association With the Federated States of Micronesia and the Republic of the Marshall Islands".
54. "8 FAM 302.2 Acquisition by Birth in the Commonwealth of the Northern Mariana Islands".
55. "Today in History – March 31".
56. "History of Samoa".
57. "American Samoa {{!}} Culture, History, & People".
58. "American Samoa".
59. IBP USA. (2009). "SAMOA American Country Study Guide: Strategic Information and Developments". Int'l Business Publications.
60. (April 10, 2017). "American Samoa and the Citizenship Clause: A Study in Insular Cases Revisionism". Harvard Law Review.
61. "Guam {{!}} History, Geography, & Points of Interest".
62. "Northern Mariana Islands {{!}} history—geography".
63. "Trust Territory of the Pacific Islands {{!}} former United States territory, Pacific Ocean".
64. Farrel, Don. (October 13, 2019). "History of Efforts to Reunify the Mariana Islands". Guampedia.
65. "Australia—Oceania :: Northern Mariana Islands—The World Factbook—Central Intelligence Agency". CIA World Factbook.
66. (September 25, 2017). "Puerto Rico's Status Explained. ECSU Takes A Look At Island's History". The Chronicle.
67. "Milestones: 1866–1898 - The Spanish-American War, 1898".
68. (July 16, 2018). "When Did Puerto Rico Become a Commonwealth?".
69. "Puerto Rico – History and Heritage {{!}} Travel {{!}} Smithsonian Magazine".
70. "The Insular Cases: A Comparative Historical Study of Puerto Rico, Hawai'i, and the Philippines". The Federal Lawyer.
71. (January 14, 2016). "The Supreme Court Ponders Whether Puerto Rico Is a Fake State or a Real Colony".
72. (June 28, 2018). "Bipartisan Bill Seeks To Make Puerto Rico The 51st U.S. State By 2021".
73. "8 U.S. Code § 1406—Persons living in and born in the Virgin Islands".
74. "Language situation in the U.S. {{!}} About World Languages".
75. "Virgin Islands Language".
76. "POVERTY STATUS IN 2009 BY AGE Universe: Population for whom poverty status is determined more information 2010 U.S. Virgin Islands Summary File". U. S. Census Bureau.
77. "U.S. Census Bureau QuickFacts: Puerto Rico". U. S. Census Bureau.
78. "Life expectancy at birth, total (years) – Puerto Rico, Guam, Virgin Islands (U.S.) {{!}} Data".
79. [https://www.cia.gov/the-world-factbook/countries/american-samoa/ The World Factbook] {{Webarchive. link. (January 29, 2021 CIA World Factbook. American Samoa. Retrieved July 4, 2019.)
80. [https://www.cia.gov/the-world-factbook/countries/guam/ The World Factbook] {{Webarchive. link. (January 26, 2021 CIA World Factbook—Guam. Retrieved July 4, 2019.)
81. [https://www.cia.gov/the-world-factbook/countries/puerto-rico/ The World Factbook] {{Webarchive. link. (January 5, 2021 CIA World Factbook—Puerto Rico. Retrieved July 4, 2019.)
82. [https://www.cia.gov/the-world-factbook/countries/virgin-islands/ The World Factbook] {{Webarchive. link. (January 13, 2021 CIA World Factbook—Virgin Islands (U.S.) Retrieved July 4, 2019.)
83. "Filling Gaps In The Human Development Index: Findings For Asia And The Pacific". United Nations Economic and Social Commission for Asia and the Pacific (ESCAP).
84. (May 14, 2017). "Human Development Index Trends and Inequality in Puerto Rico 2010–2015".
85. "American Samoa {{!}} Data".
86. (March 2014). "GAO—American Samoa and the Commonwealth of the Northern Mariana Islands—Economic Indicators Since Minimum Wage Increases Began". U.S. Government Accountability Office.
87. "2010 FIPS Codes for Counties and County Equivalent Entities".
88. "States, Counties, and Statistically Equivalent Entities (Chapter 4)".
89. "American National Standards Institute (ANSI) Codes for States".
90. (September 2012). "United States Summary: 2010. Population and Housing Unit Counts.".
91. (March 2014). "U.S. Virgin Islands Demographic Profile Summary File.".
92. (August 5, 2021). "U.S. State Boundaries – CKAN".
93. "Frequently Asked Questions to Accompany the Estimates of at Least the Top 15 Languages Spoken by Individuals with Limited English Proficiency under Section 1557 of the Affordable Care Act (ACA).". U.S. Department of Health and Human Services, Office for Civil Rights (OCR).
94. "Territorial Courts".
95. "Article IV Territorial Courts – Explained – The Business Professor, LLC".
96. "American Samoa: Issues Associated with Some Federal Court Options {{!}} U.S. GAO".
97. "ACS Demographic and Housing Estimates. 2013–2017 American Community Survey 5-Year Estimates". United States Census Bureau.
98. (March 2020). "American FactFinder". United States Census Bureau.
99. "QuickFacts – Puerto Rico". U.S. Census Bureau.
100. "Detection Screen".
101. "Gross Domestic Product for Guam, 2018 {{!}} U.S. Bureau of Economic Analysis (BEA)".
102. "Gross Domestic Product for the Commonwealth of the Northern Mariana Islands (CNMI), 2018 {{!}} U.S. Bureau of Economic Analysis (BEA)".
103. "Gross Domestic Product for the U.S. Virgin Islands (USVI), 2018 {{!}} U.S. Bureau of Economic Analysis (BEA)".
104. "GDP growth (annual %) – Puerto Rico {{!}} Data".
105. "American Samoa GDP Increases in 2018 {{!}} U.S. Bureau of Economic Analysis (BEA)".
106. (May 2017). "Making a Visible Difference In American Samoa (Final Report)". US EPA Region 9.
107. "Profile of Selected Economic Characteristics: 2010. 2010 American Samoa Demographic Profile Data". United States Census Bureau.
108. "Income in the Past 12 Months (in 2017 Inflation-Adjusted Dollars). 2013–2017 American Community Survey 5-Year estimates". United States Census Bureau.
109. "U.S. Census Bureau QuickFacts: Comerío Municipio, Puerto Rico".
110. (March 2020). "Profile of Selected Economic Characteristics: 2010. 2010 Guam Demographic Profile Data}}{{Dead link". United States Census Bureau.
111. Act of Admission, § 2, Pub. L. No. 86-3, 73 Stat. 4 (March 18, 1959).
112. "Australia-Oceania: Midway Islands".
113. "Australia-Oceania: United States Pacific Island Wildlife Refuges".
114. "Australia-Oceania: Wake Island".
115. [https://www.cia.gov/the-world-factbook/countries/navassa-island/ The World Factbook] {{Webarchive. link. (January 27, 2021 CIA World Factbook—Navassa Island. Retrieved July 4, 2019.)
116. "Geography".
117. (November 1997). "U.S. Insular Areas: application of the U.S. Constitution". U.S. General Accounting Office Report.
118. "Dependencies and Areas of Special Sovereignty".
119. Moore, John Bassett. (1906). "A Digest of International Law as Embodied in Diplomatic Discussions, Treaties and Other International Agreements, International Awards, the Decisions of Municipal Courts, and the Writings of Jurists and Especially in Documents, Published and Unpublished, Issued by Presidents and Secretaries of State of the United States, the Opinions of the Attorneys-General, and the Decisions of Courts, Federal and State". U.S. Government Printing Office.
120. (June 12, 2015). "Acquisition Process of Insular Areas". [[United States Department of the Interior]] [[Office of Insular Affairs]].
121. {{cite executive order. (May 13, 1936)
122. (June 12, 2015). "Kingman Reef". [[Office of Insular Affairs]].
123. (October 31, 2007). "DOI Office of Insular Affairs (OIA)—Palmyra Atoll".
124. "Palmyra Atoll". U.S. Department of the Interior Office of Insular Affairs.
125. "U.S. PURCHASE OF PALMYRA HITS IMPASSE {{!}} Pacific Islands Report".
126. (April 2, 2010). "The Struggle For Hawaiian Sovereignty – Introduction {{!}} Cultural Survival".
127. [[International Court of Justice]]. (2012). "Territorial and maritime dispute (Nicaragua vs Colombia)".
128. (August 2, 1986). "Maritime Delimitation Treaty between Colombia and Honduras".
129. "Non-Self-Governing Territories". The United Nations.
130. Vignarajah, Krishanti. [http://lawreview.uchicago.edu/sites/lawreview.uchicago.edu/files/uploads/77.2/77-2-PoliticalRootsOfJudicialLegitimacy-Vignarajah.pdf Political roots of judicial legitimacy: explaining the enduring validity of the 'Insular Cases'.] {{Webarchive. link. (May 14, 2013 , University of Chicago Law Review, 2010, p. 790. Viewed June 13, 2013.)
131. Romoser, James. (April 21, 2022). "Excluding Puerto Rico from safety-net benefits doesn't violate Constitution, court says". SCOTUSblog.
132. Weiss, Debra. "'Shameful' insular cases should be overruled, Gorsuch says, as SCOTUS rules against Puerto Rico resident". A. B. A. Journal.
133. {{cite case. link
134. "Consejo de Salud Playa de Ponce v. Johnny Rullan, Secretary of Health of the Commonwealth of Puerto Rico".
135. "The Insular Cases: The Establishment of a Regime of Political Apartheid (2007) Juan R. Torruella".
136. (March 9, 2015). "John Oliver Explains Outdated, Racist Logic Behind Restricting Puerto Rican Voting Rights {{!}} HuffPost Communities".
137. Love, David. (October 19, 2017). "The Insular Cases: Why Puerto Rico and the U.S. Virgin Islands Are Colonies and Not States".
138. (April 10, 1922). "Balzac v. People of Porto Rico".
139. (June 25, 1962). "Glidden Company v. Zdanok".
140. (December 2, 2008). "Consejo de Salud Playa de Ponce, et al Plaintiffs v. Johnny Rullan, Secretary of Health of the Commonwealth of Puerto Rico, portion III.iii".
141. "Tuaua v. United States, No. 13-5272 (D.C. Cir. 2015)".
142. Cordova, Andres L.. (January 29, 2018). "The contradictions of America's unincorporated territory". The Hill.
143. (June 15, 2021). "Fitisemanu v. United States".
144. (April 27, 2022). "Fitisemanu v. United States (Writ of Certiorari)".
145. (May 2, 2022). "The U.S. Supreme Court Cases Built on a "Rotten Foundation"".
146. Liptak, Adam. (May 2, 2022). "Gorsuch Calls for Overruling 'Shameful' Cases on U.S. Territories". The New York Times.
147. (April 21, 2022). "United States v. Vaello Madero".
148. Burnett, Christina Duffy. (2005). "{{notatypo". The University of Chicago Law Review.
149. Duffy Ponsa, Christina. (June 8, 2016). "Are American Samoans American?". [[The New York Times]].
150. Savage, David G.. (June 13, 2016). "Supreme Court rejects citizenship for American Samoans".
151. "About the Case – Equally American". Equal Rights Now.
152. "United States v. Vaello-Madero".
153. (April 10, 1905). "Rassmussen v. U.S".
154. Eva Lloréns Vélez. (February 13, 2017). "Is Puerto Rico On A Path To Incorporation?".
155. (May 31, 1904). "Dorr v. U.S".
156. (May 27, 1901). "Downes v. Bidwell".
157. "Puerto Rico's legal status reconsidered". Boston College Law Review.
158. {{cite case. link
159. United States Department of the Interior. (June 12, 2015). "Formerly Disputed Islands".
160. Philippine Organic Act of 1902, Ch. 1369, 32 Stat. 691
161. Jones Law of 1916, 39 Stat. 545
162. Tydings-McDuffie Act, 48 Stat. 456
163. Truman, Harry S.. (July 4, 1946). "Independence of the Philippines, Proclamation 2695 s 1946". The American Presidench Project, UC Santa Barbara.
164. Zaide, Sonia M.. (1994). "The Philippines: A Unique Nation". All-Nations Publishing Co., Inc..
165. [http://ryukyu-okinawa.net/pages/archive/rev71.html Okinawa Reversion Agreement—1971] {{Webarchive. link. (May 29, 2019 , The Contemporary Okinawa Website. Accessed June 5, 2007.)
166. Louis A. Pérez. (1998). "Cuba Between Empires: 1878–1902". University of Pittsburgh Pre.
167. Committee, America First. (January 1, 1990). "In Danger Undaunted: The Anti-interventionist Movement of 1940–1941 as Revealed in the Papers of the America First Committee". Hoover Institution Press.
168. (August 2014). "Islands on the Edge: Housing Development and Other Threats to America's Pacific and Caribbean Island Forests". U.S. Department of Agriculture.
169. "El Yunque National Forest".
170. (August 2017). "Forest Inventory And Analysis Fiscal Year 2016 Business Report". U.S. Department of Agriculture.
171. "Puerto Rico bird checklist".
172. "Northern Marianas bird checklist".
173. "Bird Checklist – National Park of American Samoa (U.S. National Park Service)".
174. "American Samoa bird checklist".
175. Platt, John R.. (May 25, 2018). "Memorializing the Wake Island Rail: An Extinction Caused by War". The Revelator.
176. "Laysan Duck".
177. "Wildlife & Habitat – Palmyra Atoll".
178. (January 25, 2016). "Avian disease assessment in seabirds and non-native passerine birds at Midway Atoll NWR".
179. "Wisdom, The Laysan Albatross".
180. (November 14, 2017). "The Case for Adding the U.S. Territories in the Caribbean to the ABA Area – 10,000 Birds".
181. "Marine mammal & reptile checklist for American Samoa". U.S. National Park Service.
182. "Pacific Sheath-tailed Bat Facts".
183. "IUCN Red List of Threatened Species".
184. "Mariana Fruit Bat".
185. (March 5, 2018). "Here's Why The Coquí Frog is the Symbol of Puerto Rico".
186. "Animals – Virgin Islands National Park".
187. "National Register of Historic Places Registration Form—Turtle and Shark". U.S. National Park Service.
188. "National Park of American Samoa".
189. "Virgin Islands National Park".
190. "War In The Pacific National Historical Park".
191. Hulse, Carl. (January 9, 2018). "Advocates of Puerto Rico Statehood Plan to Demand Representation". [[The New York Times]].
192. Wagner, John. (September 20, 2018). "Puerto Rico's governor ramps up push for statehood on anniversary of Maria". [[The Washington Post]].
193. Immerwahr, Daniel. (February 15, 2019). "How the US has hidden its empire". [[The Guardian]].
194. Bevacqua, Michael Lujan. (March 9, 2017). "Bevacqua: Guam is a colony of the U.S.". Pacific Daily News.
195. Vine, David. (September 28, 2017). "Most countries have given up their colonies. Why hasn't America?". [[The Washington Post]].
196. Stern, Mark Joseph. (March 30, 2018). "The census' new citizenship question leaves out American Samoa". Slate.