The 1924 National Origins Act (also known as the Johnson-Reed Act) instituted a much broader race-based quota system, which “sought to freeze the nation’s racial and ethnic mix as of 1920.”38 A presidential commission established under the act studied the racial composition of the American population and allocated annual quotas based on their findings.39 Under the act’s implementing framework, only residents who could trace their origins to European nations were counted as “authentic” Americans. There was no quota allotment, for example, to any African country under the National Origins Act.40 The act remained in place until its repeal in 1965, in the context of the civil rights movement, a moment when legalized white nationalism was widely perceived as “un-American.”41 America’s racialized immigration and nationality laws of this period attracted the attention of Adolf Hitler as he was composing Mein Kampf and its unpublished sequel, his “Second Book.” In that later work, Hitler wrote: American immigration policies provide confirmation that the previous “melting pot” approach presupposes humans of certain similar racial basis and immediately fails as soon as fundamentally different types of humans are involved.42 Another generally unexamined area of U.S. citizenship law that is still in effect today emanates from the United States’ colonial legacy and present-day colonialist attitudes to its “unincorporated territories.” These territories include lands acquired by the United States as a result of the Spanish-American War of 1898, among them Puerto Rico.43 In a series of cases decided just after the war, known as the Insular Cases, the U.S. Supreme Court authorized a colonial governance regime enacted by Congress that effectively limits the application of the Constitution in U.S.-held territories not “incorporated” into the United States. The decisions deployed expressly chauvinistic and racist logic in upholding Congress’s prerogative to bar full citizenship for the people living in these territories.44 Justice Brown captured the spirit of the Insular Cases in his Downes v. Bidwell (1901) opinion’s concluding remark: A false step at this time might be fatal to the development of … the American empire … [C]onditions [may be brought about] which would render the annexation of distant possessions desirable. If those possessions are inhabited by alien races, differing from us in religion, customs, laws, methods of taxation, and modes of thought, the administration of government and justice, according to Anglo-Saxon principles, may for a time be impossible.45 As some scholars have observed, and is readily clear from the other areas of U.S. law explored here, such attitudes reflect the prevailing attitudes of their time.46 The framework of these cases is still in place, however, generating a steady—if virtually unnoticed—stream of campaigns to alter the U.S. position on the rights of inhabitants of so-called “insular areas” (territories).47 The Constitution does not mention the word “colony” which, as Judge Juan R. Toruella of the U.S. Circuit Court of Appeals for the First Circuit (which includes the territory of Puerto Rico) opined, “is not surprising given that the War for Independence was fought to I. History and Context 23