A Dramatization of the In re Rodriguez case 1897

Introduction

What follows is a dramatization of the In re Rodriguez case from 1897. This case marked the first time a Mexican citizen, living in the United States, applied for naturalization in federal court and had their application contested. Among other issues, the case centered on the question as to whether Mexicans could apply for U.S. naturalization given the immigration laws that specifically limited naturalization to “free white persons” (1790)^[1] and “aliens of African nativity and to persons of African descent” (1870).^[2]

The case established a precedent wherein Mexican Americans became defined as legally white. Or, as Ariela Gross summarizes it, “white by treaty.” This status of legal whiteness—which is distinct from any social experience of whiteness and white privilege—is precisely the paradoxical position the lawyers in Hernandez v. Texas (1954) wanted to expose as unacceptable and discriminatory in effect. What was debated and decided in In re Rodriguez is essential to understanding the arguments in Hernandez v. Texas.

The actual court record of In re Rodriguez (81 F. 337) is dense and difficult to read. It consists mainly of the amicus curiae briefs of attorneys McMinn, Evans, and Paschal, and the decision by Judge Maxey. The dramatization of the court record that follows is meant to help students understand the historical facts of the case, the main subjects and concerns debated, and the focus and logic of Judge Maxey’s decision. While no such transcript of an actual legal hearing exists, much of the language and all of the ideas in this dramatization are drawn from the published In re Rodriguez court record, which should also be made available to students.

In re Rodriguez, the Play

Setting: Federal Courthouse, San Antonio, Texas, 1897.

Characters:

• Ricardo Rodriguez, 37 years old, born in Mexico, resident of Texas since 1883, speaks no English
• Thomas M. Paschal, appointed “friend of the court,” lawyer in support of Rodriguez’s application
• Andrew J. Evans, appointed “friend of the court,” lawyer against Rodriguez’s application
• Theodore J. McMinn, appointed “friend of the court,” lawyer against Rodriguez’s application
• Thomas Maxey, Presiding Judge, U.S. District Court for the Western District of Texas
• Translator, appointed by the court
• Demonstrators, a group of at least 14 people, carrying signs and shouting opinions; half in support of the Rodriguez application, half against

SCENE ONE

(The lights come up on a tiered stage. There are three platform levels on which, once the play begins, the lawyers (1st level up), the witnesses (second level up), and the judge will sit (top-level). At the beginning of the play, these tiered platforms serve as steps outside a courthouse on which demonstrators stand; once the play begins, the platforms will serve as the seated levels in the courtroom in the interior of the courthouse.

At the back of the stage, covering the whole back wall is a white projection screen (called “backscreen” in the following script) on which is cast many images throughout the play. In the first scene, an image of a typical courthouse is projected on the backscreen, behind demonstrators, so it appears that a demonstration is occurring on the front steps of the courthouse.

The demonstrators crowd the two sides of the steps. On one side are pro-Rodriguez demonstrators, and on the other side are anti-Mexican naturalization demonstrators. Certain demonstrators shout angry anti-immigration/naturalization slogans as the other side loudly voices their support of Ricardo Rodriguez and the Mexican American naturalization cause.

After 90 seconds of this loud, somewhat chaotic demonstration, the lights go down. In this blackness, tables and chairs are brought in and arranged on the stage to fit the structure of a typical interior courtroom.)

SCENE TWO

(There is a table for the lawyer arguing for Rodriguez’s application (with Rodriguez sitting next to him), a table for the two lawyers arguing against Rodriguez’s effort, a chair at center stage for witnesses (at the beginning it will face the lawyers’ tables; a little way into the play, the witness chair will rotate to face the audience), and a judge’s bench elevated above all. All tables and seats are built upon tracks embedded in the stage so the tables and seats can rotate in angled positions and be moved between the back and front of the stage.

As the lights come up, the interior of a district courtroom is projected on the large backscreen behind the actors.

The presiding judge, Judge Maxey, takes a verbal attendance.)

Judge Maxey: “Speaking against Ricardo Rodriguez’s application for American citizenship are attorneys A. J. Evans and T. J. McMinn. Mr. Evans and Mr. McMinn, are you present?”

Evans and McMinn both stand: “Yes, your Honor.”

Maxey: “Speaking in support of Mr. Rodriguez is attorney, T. M. Paschal. Mr. Paschal, are you present?”

At his table, Paschal stands: “Yes, your Honor.”

Maxey: “Very good, let us begin. This District Court, located in San Antonio, Texas, will now hear arguments for and against the application submitted by Ricardo Rodriguez, a citizen of Mexico, to become a naturalized citizen of the United States. Mr. Evans, you will begin these proceedings and you now have the floor.”

Evans: “Thank you, your Honor. I would like to first call Ricardo Rodriguez, the applicant, to the stand.”

(Ricardo Rodriguez rises from the table where he sits next to Paschal and walks to the witness stand. As he does so, photographs from the outside demonstration flash across the backscreen, with people furiously waving signs both for and against Rodriguez’s application.

As Rodriguez takes the stand and swears on a Bible, the three colors of the Mexican flag begin to light up, slowly, on the backscreen and across his body. Next to Rodriguez stands a court interpreter, but no such colors appear on him. For the first two questions, the translator translates between the lawyers and Rodriguez, but at the third question, the translator fades to black and departs the stage.)

Evans: “Please state your name, your age, and your citizenship for the court.”

(The translator translates this into Spanish for Rodriguez.)

Rodriguez, struggling to express his words in English: “I am Ricardo Rodriguez, I am 37 years old, and I am a citizen of Mexico. But I have lived in Texas for many years.”

Evans: “Yes, well, living here is not the same as being a citizen here, Mr. Rodriguez. The latter is a privilege for the few and the deserving.”

(As Evans says this, the translator quietly translates these words to Mr. Rodriguez, and then fades to black. The conversation then proceeds directly between the lawyers and the witness.)

Evans: “Mr. Rodriguez, in your first application hearing you claimed that you are a ‘pure-blooded Mexican.’ What does this mean? Do you believe that you belong to the Aztec race in Mexico?”

Rodriguez: “No, sir.”

Evans: “Where did your race come from? Spain?”

Rodriguez: “No, sir.”

Evans, insistently: “Where did your race come from?”

Rodriguez: “I do not know where they came from.”

Evans, expressing some frustration: “Okay, but you said you’re a ‘pure-blooded Mexican.’ Does your family claim any religion? What religion do they profess?”

Rodriguez: “Catholic religion.”

(Evans looks meaningfully at the Judge and then the audience, and then sits down.)

McMinn rises to speak: “Hello, Mr. Rodriguez. In your original application claiming an intent to naturalize, your representative stated that you are ‘attached to the principles of the constitution of the United States.’ Could you please identify what basic principles of the constitution you understand and support?”

(At this moment, the colors of the Mexican flag begin to fade, being replaced by the red, white and blue of the American flag, but these colors appear as bars across Rodriguez’s body.)

Rodriguez looks confused and anxious. He shakes his head and states: “I don’t understand. I don’t speak English well.”

McMinn: “Okay, you say you know the U.S. Constitution. Can you identify two or three ideas in it? Or even one idea?”

Rodriguez: “I’m sorry. I still don’t understand.”

McMinn: “What makes you think you can be a good citizen of a country when you do not even know the country’s rules?”

Rodriguez: “I *am* a good person! I follow the rules! I have been here for 10 years and I work hard! I’m good!”

McMinn: “Hmmmm. Well, let me help remind you.”

(McMinn puts in front of Rodriguez a sheet of paper with the first three paragraphs of the U.S. Constitution. This excerpt is projected behind Rodriguez on a large screen. The words appear across Rodriguez’s body too, and he attempts to read his arms and torso.)

McMinn: “Please read this document aloud for the court.”

Rodriguez: “I’m sorry, I can’t.”

McMinn: “Okay, if you find this difficult, please just read the first paragraph and tell the court what it means.”

Rodriguez, looking confused and fearfully at his arms and torso, states: “I’m sorry, I don’t know how to read.”

McMinn: “Don’t know how to read, or don’t know how to read English?”

Rodriguez, says holding up his hands: “I never went to school. I was working. Road work. That’s what I do here in this country. Every day. A hard worker. A good worker.”

McMinn: “Hmmmm. No more questions.”

(While McMinn sits down, Rodriguez sits by himself, staring at his hands in a way suggesting shame. The video projected text of the Constitution turns off.)

SCENE THREE

Judge Maxey: “Mr. Rodriguez, you may return to your seat. Mr. Paschal, do you have a witness you’d like to call?”

Paschal pats Rodriguez on the back as he sits down, then says: “Yes, your honor. I’d like to call Mr. J. G. Fisk to the stand.”

(Rodriguez sits straighter, more proudly, and begins a bit of a smile when he hears Fisk’s name.

Fisk rises from the court seats, makes his way to the stand, and is sworn in.)

Paschal: “State your name please.”

(Fisk states his name.)

Paschal: “Mr. Fisk, you are here in support of Mr. Rodriguez’s application for naturalization?”

Fisk: “Yes.”

Paschal: “I see by your affidavit that you are acquainted with the applicant. For how long? How long have you known him?

Fisk: “I couldn’t say exactly, but it has been in the neighborhood of ten years.”

Paschal: “Well, do you know anything about his ancestry?”

Fisk: “No, sir. No more than judging by his appearance, and about what he had told me previously—that he was of pure blood.”

Paschal: “I see that you made an affidavit saying that he is a good moral character and attached to the principles of the Constitution of the United States. What reasons did you have for saying this? Did you have any intimation that he had any knowledge of the principles of the Constitution?”

Fisk: “Not exactly, but I know the man. I know that he is a good man, and know that if, whatever the principles of the Constitution might be, that he would uphold them.”

Paschal: “Has he been a peaceable citizen?”

Fisk: “Yes, sir; a very good man.”

Paschal: “A hard-working citizen?”

Fisk: “Yes, sir.”

Paschal: “Do you know what his occupation has been?”

Fisk: “He has been working for the city for the greater part of 10 years; that is, working on the ditches, cleaning the ditches and river.”

Paschal: “A man of good moral character, a good, law-abiding citizen?”

Fisk: “Yes, sir; to a remarkable degree.”

Paschal: “Thank you, Mr. Fisk. Your honor, I have no more questions.”

(Paschal goes to sit down, and the seats in the room rotate so that Mr. Rodriguez sits in a chair at the front of the room, facing the audience, and Evans, McMinn, Paschal, and Maxey are on tiered elevated platforms behind him. The two lawyers’ tables combine, and Evans, McMinn and Paschal sit at one table. The chair of each lawyer moves to the position at the table closest to the audience when they are the lead speakers. As this happens, the other lawyers’ chairs move downstage.

Evans stands first, addressing Maxey. The Judge sits at his judge’s stand, on a tier just above Evans, looking and listening to the lawyers.)

SCENE FOUR

Evans: “Judge, I move that this hearing be ended immediately. The applicant, Mr. Rodriguez, has nothing. As he himself said, he’s a native-born person of Mexico, and one of the original races found in Mexico when Cortez conquered it in 1519. He’s got no standing to be naturalized under the laws of the United States.”

(McMinn’s chair rotates around to the forefront of the table as he begins speaking to Maxey. As he speaks, a silent Rodriguez begins to look at his hands and to touch his face and hair, intermittently looking out at the audience. He expresses a mixture of confusion and pride.)

McMinn: “He’s right, your honor. Mr. Rodriguez admits to being a ‘pure-blooded Mexican.’ You saw him. I mean, just look at him! [gestures toward Rodriguez] This means that he’s a Mexican Indian. An Indian! And in this country, Indians cannot be naturalized. The Supreme Court said so in Elk v. Wilkins in 1884. The majority opinion held that Indians hold inalienable allegiance to the tribe they’re born into. The identity and allegiance created by being born into a tribe are everything, in legal terms. Individually, they cannot become citizens of the United States! As the majority opinion in Elk v. Wilkins stated, ‘National legislation has tended more and more toward the education and civilization of the Indians, and fitting them to be citizens. But the question of whether any Indian tribes, or any members thereof, have become so far advanced in civilization that they should be let out of the state of pupilage, and admitted to the privileges and responsibilities of citizenship, is a question to be decided by the nation whose wards they are and whose citizens they seek to become, and not by each Indian for himself.’ You see your Honor, Indians are not fit to decide for themselves, and more to the point for this case, Indians can’t individually choose to be American citizens!”

(Towards the end of McMinn’s speech, his chair begins to shift backward and Evans’s chair comes forward.)

Evans: “Your honor, my esteemed colleague is correct, but he’s gotten caught up in a subset of issues. It doesn’t really matter if the applicant, Mr. Rodriguez, is Indian, what really matters is that he is NOT WHITE! Or African. Or of African descent. When Congress first enacted a naturalization law, it was quite clear on the color and the race of desirable immigrants. Congress stated quite clearly in 1790, “any alien, being a free white person” may be admitted to become a citizen. Okay, this became a problem after the Civil War, with that old 1857, pre-Civil War, Dred Scott v. Sandford decision (saying that persons of African descent were not and could not become U.S. citizens), but Congress fixed this with the Naturalization Act of 1870. Citizenship that was available to free white persons now, in the words of the law, extends “to aliens of African nativity and to persons of African descent.” Simply put, your honor, white people and black people—these are persons deemed eligible for and worthy of citizenship. In quite clear legal terms, you don’t see Indians listed and you don’t see Mexicans listed!”

(McMinn’s chair comes forward and he rises to speak as Evans sits down. As Evans’s chair moves to an upstage position at their table, he fans his now heated face. As Evans’s voice and gestures have become more animated and passionate in the previous speech, Rodriguez has turned awkwardly in his chair to look at him. While McMinn now speaks, Rodriguez turns back to the audience, slumps in his chair, and his body becomes covered by a video-projected red circle with a line through it.)

McMinn: “Your honor, my colleague has become impassioned around this passionate issue. Let me come in here to clarify and substantiate his worthy argument. As Mr. Evans explained, the federal law of 1870 limits the right of naturalization to white persons and persons of African descent. The explicit words of this law must be held to have a natural and ordinary meaning as to whom they apply. This issue has been tested and decided numerous times in court. Think to U.S. District Court

Judge, Justice Deady, who in In re Camille, 1880, made the point, ‘From the first, our naturalization laws only applied to the people who had settled the country, the European or white race.’ Or refer to the earlier 1878 federal case, In re Ah Yup, upon which Justice Deady based his decision. In re Ah Yup, a Chinese immigrant applied for U.S. citizenship. He argued that the term white in federal naturalization law could be interpreted to include persons of Asian origin. The applicant’s lawyer argued that the words white person constitute a very vague description of a class of persons, none of whom can be said to be literally white. In fact, those called white in everyday speech may be found to be every shade, from the lightest blonde to the most swarthy brunette. BUT, your Honor, the judge in that case rejected this argument—he left white to white people, and you and I know who those are! Quite explicitly, the judge in In re Ah Yup stated, ‘As ordinarily used everywhere in the United States, one understands that the party employing the words white person intends a person of the Caucasian race.’ As a self-proclaimed pure-blooded Mexican, and as a person who doesn’t even look white, Mr. Rodriguez is not eligible to apply for citizenship. This all means, your Honor, that Rodriguez’s application for naturalization should fail!”

(As McMinn finishes his speech and goes to sit down, videos appear projected on the back wall and across Rodriguez’s body of cheering demonstrators—those persons in and outside of the courtroom who are against the ability of Mexicans to apply to become U.S. citizens. As those demonstrators cheer, we see Rodriguez slumping in his chair, head down, and intermittent images of pro-Rodriguez/Mexican naturalization demonstrators looking dismayed at McMinn’s words.)

SCENE FIVE

(Amidst all this, Rodriguez’s lawyer, T. M. Paschal’s chair rotates to the forefront of the table, and he rises to address Judge Maxey.)

Paschal: “Your Honor, [gesturing at McMinn and Evans] as esteemed as these men might be, and as impassioned as their arguments seem, they are, quite simply, wrong in their claims and in their understanding of United States legal history. A legal history that makes clear that Mexican persons, and Ricardo Rodriguez in particular, have sound eligibility to apply for U.S. citizenship. My explanation of this legal history, and its affirmative applicability to Mr. Rodriguez, will not be grounded in pseudo-scientific ethnography or murky racial classifications. Instead, my argument will focus on the history of border relations between Mexico and the United States, both as friends and foes. I will center the Treaty of Guadalupe Hidalgo in determining the eligibility of citizenship for persons of Mexican descent.

While racial identity certainly does matter in legal assessments of naturalization eligibility, Mr. McMinn and Mr. Evans are wrong in their arguments about how strictly the word “white” has been culturally understood and politically assessed.”

(As Paschal organizes his papers and begins to speak the following lines, earlier photos of the first three paragraphs of the Constitution, the large red circle with a line across it, different flags of different nations, and stills of the two groups of demonstrators begin to flash on the backscreen and across Rodriguez’s body.)

Paschal: “First, let me be clear, our government needs to limit and protect the sacred status of U.S. citizenship. We all will agree that no graver responsibility rests on the jurists, legislators, and citizens of this republic than to see that the greatest quantity of intelligence, education, and morality is present in our national collective. These merits must be most present in those who are charged with handing down to the next generations our free institutions and best traditions. To this end, legal agents such as these men [gesturing at McMinn and Evans] have as their greatest duty to guard the outer and inner doors of the sanctuary of American citizenship, in case unworthy persons should try to enter.”

(While Paschal is declaring the following lines, the photos on the background screen turn to historical cartoon caricatures of Chinese immigrants from the mid-to-end of the nineteenth. These real-life political comics are racist, raw, and cruel. Across the body of Rodriguez is projected, steadily, the Mexican flag.)

Paschal: “As an example of such necessary vigilance, I will return to the case cited by Mr. McMinn, In re Ah Yup. Mr. McMinn was wrong to reference this case as a means to argue against the eligibility of Ricardo Rodriguez—Mexicans are NOT Chinese—but the decision in that case does make clear the need for careful and vigilant citizenship rules. In In re Ah Yup, the judge, Justice Sawyer, made clear that the Chinese or Mongolian race was explicitly excluded by Congress when the 1870 naturalization law was debated and enacted. Judge Sawyer stressed that the fear of Mongolian citizenship arose from our highest national policy concerns. The Chinese race is not only alien in color, but is—in all things that make for good citizenship—the very opposite of the white and even native American races. In contrast to, for example, Mexicans like Mr. Rodriguez, a Chinese person is totally unable to assimilate to our country’s laws and customs—he is utterly alien in his mode of living, his religion, and even his dangerous vices. Even more concerning, countless hordes of Chinese wait on the waters and the borders, ready and anxious to swarm upon us. As should be obvious to all here, this menace certainly does not exist with our Mexican neighbors!”

(The projection of racist political cartoons on the screen and the Mexican flag on Rodriguez ends abruptly, and as Paschal speaks the following lines, an American flag appears slowly on Rodriguez’s body, seeming to enwrap him.)

Paschal: “Now, to return to the subject at hand, the eligibility of Mr. Rodriguez for naturalization, let me state the central facts. U.S. citizenship may be attained in one of the following ways: 1) by birth; 2) by compliance with our naturalization laws; and 3) by collective naturalization, as when a country or territory becomes incorporated within our nation by means of conquest, cession, or free gift. In this third case, a treaty customarily ratifies such annexation and allows residents within the annexed territory a certain time either to preserve the nationality of their origin or to become naturalized citizens of our United States. This political process is precisely what happened with the 1848 Treaty of Guadalupe Hidalgo. Quite simply, according to this treaty, Mexican citizens of California, Texas, and the like, who remained in the conquered territory, became citizens of the United States. Mexicans were naturalized as U.S. citizens! In addition, as directed by U.S. judicial review, nationality obtained in this collective manner was as sound and valid as any individual petitioner’s compliance with naturalization law.”

(At this point, Paschal puts up his hands as if to say “SEE!” gesturing toward Judge Maxey, and then out to the general theater audience.

At this point, lights fade on the lawyers’ table and the table moves back, offstage. Judge Maxey descends from his stand, comes to the front of the stage, and begins intermittently to look closely at Rodriguez, as he paces in deep thought.)

SCENE SIX

(After some time passes, and as he offers his decision on the case, Judge Maxey repeatedly circles Rodriguez as he speaks to both Rodriguez and the general audience. Rodriguez has the difficult task of both listening attentively to Judge Maxey and not understanding a word he says.)

Judge Maxey, delivering the opinion of the court: 

“The court recognizes the delicacy and significance of the question which this application involves. This is the first such case of its kind. Although 49 years have passed since the Treaty of Guadalupe Hidalgo, which greatly increased U.S. territory and incorporated many thousands of Mexicans into our common citizenship, this is the first time an individual application by a Mexican citizen has made its way to this court. So the question is, why may Mr. Rodriguez not be naturalized under the laws of Congress? The most recent federal naturalization law reads, “The provisions of this title shall apply to aliens being free white persons and to aliens of African nativity and to persons of African descent.” Therefore the argument against Mr. Rodriguez is that as a Mexican citizen, he is, because of his race and color, denied the right to become naturalized as an American. This court believes that such a legal focus is misdirected.”

“To explain: some of the arguments offered in this case have revolved around the word white in federal naturalization laws. Counsels opposing Mr. Rodriguez’s application have argued that, according to both published scientific beliefs and in-person visual appraisals, Mr. Rodriguez is not white and this status should negate his eligibility for naturalization. Such arguments limit what is defined as white to persons of European, specifically Caucasian, descent. In the 1894 case, In re Saito (62 Fed. 126), the presiding judge, Justice Colt, asserted that when the naturalization laws were established at the turn of the 18th century, “the country was inhabited by three races: The Caucasian, or white, race; the negro, or black, race; and the American, or red, race. It is reasonable…to infer that when Congress, in designating the class of persons who could be naturalized, inserted the qualifying word ‘white,’ it intended to exclude from the privilege of citizenship all alien races except the Caucasian.”

“In contrast to this line of argument, counsel in support of Mr. Rodriguez’s application has argued that social and political understandings of what persons are white have long been under question in American legal proceedings. Mr. Paschal correctly argues that the only race of persons clearly prohibited by current naturalization law are aliens of Mongolia—namely, persons of Chinese descent. As stated clearly in Section 14 of the Congressional Act of May 6, 1882, “hereafter no state court or court of the United States shall admit Chinese to citizenship; and all laws in conflict with this act are hereby repealed” (22 Stat. 61).”

“However, such debates about what persons are and are not white do not, in fact, exactly pertain to the case of Mr. Ricardo Rodriquez. Mr. Rodriguez’s genealogy and bodily features do not so much matter in this case as do the series of geographic and political treaties between the United States and Mexico since 1836, at the least. Since that date, with the legal statehood of Texas, and on border land that has been claimed by and ceded to the United States, former citizens of Mexico have been collectively naturalized as U.S. citizens. Such collective naturalization of former Mexicans has occurred in Texas, Nebraska, California, New Mexico, and Utah.”

“To make the pertinent facts absolutely clear: citizenship in this country may be acquired in one of four ways: 1) by birth; 2) by compliance with naturalization laws; 3) by constitutional amendment; and 4) by collective naturalization. This last process, central to U.S.-Mexico history and highly pertinent to this case, occurs where a country or contested area becomes incorporated in the United States by conquest or cession. The treaty which ratifies such annexation usually allows a time limit wherein each resident within the annexed territory can preserve the nationality of his origin or will become legally naturalized as a U.S. citizen by means of this annexation.”

“This is precisely what happened with the Mexican citizens who were inhabiting the geography of Texas after the U.S.-Mexico War of 1846-1848. With the U.S. victory and the Treaty of Guadalupe Hidalgo, those persons, previously of Mexican citizenship, became naturalized as U.S. Citizens. The 1848 Treaty declared that, one year after the date of the signed treaty, those Mexicans who remained “in the said territories…without having declared their intention to retain the character of Mexicans, shall be considered to have elected to become citizens of the United States.” As I said earlier, this process of collective naturalization of Mexican persons happened in many other states too, according to both federal citizenship law and state property laws.”

“When all such laws, treaties, and constitutional provisions are considered, which either formally confer the rights of U.S. citizenship upon Mexicans on newly gained U.S. land, or tacitly recognize the collective right of such Mexicans to naturalize, the conclusion forces itself upon the mind that citizens of Mexico are eligible for American citizenship.”

“Whatever may be the status of his application viewed from the standpoint of an ethnologist or a scientist concerned with race divisions, Mr. Rodriguez is embraced within the spirit of our naturalization laws. There is a legal history and a legal logic that must be adhered to here.

• Fact one: in 1848, the year of the Guadalupe Hidalgo Treaty, only free whites could naturalize according to federal law.
• Fact two: in 1848, according to the Treaty, citizens of Mexico who remained living in Texas became naturalized American citizens.
• Fact three: therefore, former Mexicans who naturalized as U.S. citizens in this way must have been assessed as white by treaty and law.

This court thereby presumes Mr. Rodriguez to be legally white. His application should be granted if he is shown to be a man attached to the principles of the Constitution.”

“In sum, Mr. Rodriguez, the court finds that you are eligible to apply for naturalization.”

About the author: Dr. Yukins received her MA and PhD degrees from the University of Pennsylvania. She specializes in twentieth-century American literature, particularly critical race theory, women’s studies, law, and literature.

Students are invited to engage with these complex issues through these related assignments.