The Indignity Of A False Citizenship 229 Court of Puerto Rico, which found that Mari Brás was still a citizen of Puerto Rico even though he was no longer a US citizen, and that he was eligible to vote.34 After the Puerto Rican Supreme Court’s ruling was issued, the com­ monwealth’s Department of State issued its first certificate of Puerto Rican citizenship to Mari Brás.35 Mari Brás affirmed that he had freed himself ‘from the indignity of a false citizenship, that of the country that invaded mine, which continues to keep the only country that I owe allegiance to as a colony.’36 However, the independentista cause did not prevail in federal courts. In 1998, Alberto Lozada Colon, a US citizen born in Puerto Rico, challenged the decision of the United States State Department denying him a certificate of loss of nationality despite his oath of renunciation.37 The Court held, inter alia, that Lozada Colon had failed to establish the statutory requirement that he actually intended to relinquish citizenship because he had continued to live in the United States, ie Puerto Rico. The Lozada Colon case seemed to serve as a wake-up call to the federal government, which then changed its position regarding Juan Mari Brás: just weeks after the Lozada Colon opinion was issued, the US State Department revoked Mari Brás’ renunciation of citizenship.38 4 Analysis under International and Domestic Law on Citizenship and Statelessness This article now turns to an analysis of the renunciation of US citizenship by Puerto Ricans through the lens of statelessness. As a preliminary matter, it must be determined whether Puerto Rican citizenship is distinct from US ­citizenship in terms of international law. Although US and Puerto Rican law have established the existence of Puerto Rican citizenship (see discussion in Section 2 above), ‘citizenship’ in this sense refers to domicile, guaranteeing 34 35 36 37 38 Ramirez de Ferrer v Juan Mari Bras (n 32) 198-199. See Roberto J Sanchez Ramos, Department of Justice of Puerto Rico Consulta No 06-56-B (2006). ‘The [certificate] is valid as an ID in Puerto Rico, but not recognized outside the island.’ Hevesi (n 24). Hevesi (n 24). Alberto O. Lozada Colon v US Department of State, [1998] 2 F Supp 2d 43 (DDC). ‘Berrios: Decision on Mari Bras Shows PR Still a Colony’ The San Juan Star/Associated Press (7 June 1998) <http://www.puertorico-herald.org/issues/vol2n10/maribras-berrios .html> accessed 25 August 2013. tilburg law review 19 (2014) 223-235