Isabel González (May 2, 1882 – June 11, 1971) was a Puerto Rican activist who helped pave the way for Puerto Ricans to be given United States citizenship. As a young unwed pregnant woman, González had her plans to find and marry the father of her unborn child derailed by the United States Treasury Department when she was excluded as an alien "likely to become a public charge" upon her arrival in New York City. González challenged the Government of the United States in the groundbreaking case Gonzales v. Williams (192 U.S. 1 (1904)). Officially the case was known as Isabella Gonzales, Appellant, v. William Williams, United States Commissioner of Immigration at the Port of New York No. 225, argued December 4, 7, 1903, and decided January 4, 1904. Her case was an appeal from the Circuit Court of the United States for the Southern District of New York, filed February 27, 1903, after also having her writ of habeas corpus (HC. 1-187) dismissed. Her Supreme Court case is the first time that the Court confronted the citizenship status of inhabitants of territories acquired by the United States. González actively pursued the cause of U.S. citizenship for all Puerto Ricans by writing letters published in The New York Times.
González was born and raised in San Juan, Puerto Rico when the island was still a possession of the Spanish Crown. Therefore, she was a native inhabitant of Puerto Rico and a Spanish subject, though not of the Peninsula (Spain). Her parents were Severo González and Antonia Dávila. She was residing in the island on April 11, 1899, the date of the proclamation of the Treaty of Paris of 1898 which ceded the island to the United States. One of the conditions of the treaty was to transfer by cession the allegiance of the islanders to the United States. González was a citizen of Puerto Rico, but not of the United States even though the island was governed by that nation.
González's fiancé traveled to New York City in 1902, leaving her behind, pregnant and with another child from a previous marriage (she was a widow). He went with the intention of finding a job in a factory in Linoleumville, Staten Island, in the neighborhood where Isabel's brother Luis González worked. González was to join her fiancé there and they were to marry after he found a place to live.
Situation in Puerto Rico pre-1904
Under the terms of the Treaty of Paris of 1898 which was ratified on December 10, 1898, Puerto Rico was annexed by the United States after the 1898 Spanish–American War. Spain had lost its last colony in the Western Hemisphere. The United States established a military government which acted as both head of the army of occupation and administrator of civil affairs. Almost immediately, the United States began the "Americanization" process of Puerto Rico. The U.S. occupation brought about a total change in Puerto Rico's economy and polity and did not apply democratic principles in their colony. Puerto Rico was classified as an "unincorporated territory" which meant that the protections of the United States Constitution — including the right of citizenship — did not automatically apply, because the island belonged to the U.S., but was not part of the U.S.
On January 15, 1899, the military government changed the name of Puerto Rico to Porto Rico (On May 17, 1932, the U.S. Congress changed the name back to "Puerto Rico") and the island's currency was changed from the Puerto Rican peso to the American dollar, integrating the island's currency into the U.S. monetary system. The United States exerted its control over the economy of the island by prohibiting Puerto Rico from negotiating commercial treaties with other nations, from determining tariffs, and from shipping goods to the mainland on other than U.S. carriers.
Opposition to U.S. citizenship for Puerto Ricans
There were various factors which contributed to the opposition of giving United States citizenship to Puerto Ricans by the Government of the United States. The U.S. Congress was reluctant to fully incorporate Puerto Rico because its population was deemed racially and socially inferior to that of the mainland. In 1899, a letter to the editor published in The New York Times described Puerto Ricans as "a light-hearted, simple-minded, harmless, indolent, docile people," claiming that "while they gamble and are fond of wine, women, music, and dancing, they are honest and sober," but compared them to "children" who lacked "sufficient knowledge to govern themselves" and were in need of education as to "what government of the people means."
Prior to 1898, the United States had organized new acquisitions from non-tribal governments into largely self-governing territories as a prelude to statehood and had generally extended broad constitutional protections and U.S. citizenship to free, non-tribal residents. After 1898, this process changed, and Congress established a centrally controlled administration in Puerto Rico, declining to recognize Puerto Ricans as U.S. citizens. As a result, many Dominicans started marrying Puerto Ricans in greater numbers in order to stop immigration problems at US ports of entry. After 1917, the citizenship of Puerto Ricans became transferable to some nationalities, mostly from Latin America, such as the Colombians and Venezuelans.
In the Downes v. Bidwell case of 1901, the U.S. Supreme Court acknowledged that the U.S. Constitution functioned differently in Puerto Rico from the way it did on the mainland. Justice Edward Douglass White introduced the concept of unincorporated territories and reasoned that, unlike prior territories, Puerto Rico had not been incorporated by Congress or by treaty into the U.S. union. It was thus "foreign to the United States in a domestic sense", that is, foreign for domestic law purposes, yet also part of the United States under international law. The decision permitted the establishment of unequal, undemocratic polities in such territories, did not demand that those territories eventually be incorporated, and granted wide latitude to Congress and the executive in structuring those polities.
González travels to New York City
In August 1902, González boarded the S.S. Philadelphia, a small Red D Line steamship that departed from San Juan, Puerto Rico, with the Port of New York as its destination. She sent a telegram to her family about her expected arrival, which would normally be at the docks of New York. But while the S.S. Philadelphia was en route, the United States Treasury Department's Immigration Commissioner General F. P. Sargent issued new immigration guidelines that changed González's and her fellow countrymen's status to that of aliens. Gonzalez and the others arrived on August 4, 1902, and were transferred to Ellis Island.
The new commissioner of immigration at Ellis Island was William Williams, a former Wall Street lawyer. He was aggressively leveling the statutory bar on those aliens "likely to become a public charge", and he was strictly enforcing immigration laws. Williams directed inspectors to treat aliens as suspect if traveling with less than ten dollars. He also instructed his inspectors to attach the label of "public charge" to unmarried mothers and their children, despite most of them already expecting to receive a job upon admission to the United States. Ellis Island policy dictated that "unmarried pregnant women were always detained for further investigation" and that single women were released only if family members came to claim them.
González was detained by the Immigration Commissioner at that port as an "alien immigrant" so that she might be returned to Puerto Rico if it appeared that she was likely to become a public charge. Gonzalez had eleven dollars in cash on her person and her family was to pick her up, however the immigration officials discovered her pregnancy during her early line inspection and a Board of Special Inquiry opened a file on her (her surname was later misspelled as "Gonzales" by immigration officials).
A hearing was held the next day and González's uncle, Domingo Collazo, and her brother, Luis González, joined her (her fiancé did not appear, as he was not permitted to miss work). During the hearings, the family focused on the question of preserving González's honor and bringing her to New York. Inspectors weighed proof of legitimate family relations against presumptions that certain kinds of women were inadequate mothers and certain kinds of men were insufficient fathers and husbands. Williams said: