The United States of America, as a name, is slightly misleading. It’s true that this country consists mostly of fifty states bound together in a federal union. It’s also true that, for various historical reasons, the United States also includes a constellation of territories that it acquired in the 19th and early 20th centuries. Some of these lands, like Hawaii and Alaska, have since joined the Union as states. Others, like the Philippines, are now independent countries.And then there are some, most famously Puerto Rico, that occupy a liminal space in the American empire. In a concurring opinion last week in United States v. Vaello-Madero, Justice Neil Gorsuch sought to close that gap by rev
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