Downes v. Bidwell

law case

Written by

The Information Architects of Encyclopaedia Britannica

Last updated

June 25, 2026

Quick Summary

In Downes v. Bidwell (1901), the U.S. Supreme Court ruled that Puerto Rico was a non-incorporated territory. This meant that Puerto Rico did not have the full protections of the U.S. Constitution, and its inhabitants were not automatically U.S. citizens.1

The U.S. occupied Puerto Rico in 1898. The Foraker Act of 1900 established the island as an unorganized territory. The Supreme Court's decision in Downes v. Bidwell affirmed this status, stating that Puerto Rico was never intended to be a U.S. state. While Puerto Ricans have since been granted citizenship and constitutional protections, the island's territorial status has remained a subject of debate.1

Summary created from Britannica articles using AI. AI can make mistakes, so verify using Britannica articles.

2 Britannica Sources

Ask Britannica AI about this topic

Britannica doesn't have a full article on this topic, so we've curated a list of our relevant coverage.

Henry Billings Brown
…a controversial opinion concurring in Downes v. Bidwell (one of the Insular Cases), in which he declared that peoples of annexed territories were not entitled to constitutionally guaranteed rights and privileges.
Read More
…a controversial opinion concurring in Downes v. Bidwell (one of the Insular Cases), in which he declared that peoples of annexed territories were not entitled to constitutionally guaranteed rights and privileges.
Read More

Edward Douglass White
In a concurring opinion in Downes v. Bidwell (1901), one of a group called the Insular cases, White argued that “incorporation” into the United States, by treaty or statute, determined the availability of constitutional safeguards to residents of a new U.S. possession. This vague criterion was adopted by a majority…
Read More
In a concurring opinion in Downes v. Bidwell (1901), one of a group called the Insular cases, White argued that “incorporation” into the United States, by treaty or statute, determined the availability of constitutional safeguards to residents of a new U.S. possession. This vague criterion was adopted by a majority…
Read More