The Case of In re Rodriguez
Only a few years prior to the 1903 strike in Clifton-Morenci, the case of In re Rodriguez demonstrated how unclear, yet very critical, citizenship status for Mexicans living in America was. Although The Treaty of Guadalupe Hidalgo (1848) officially gave former Mexican citizens that now resided in American territory the opportunity for U.S. citizenship, these formal protocols were also widely governed by people’s own perceptions and definitions of race.[i] In 1897, the case of In re Rodriguez became a struggle over whether Mexicans had the right to naturalize.
In 1896, Ricardo Rodriguez, a 37 year-old born in Mexico, applied for citizenship after having lived and worked in Texas for the past ten years. The Naturalization Board denied his application after concluding that the applicant was “not a white person.” When Rodriguez appealed his denial to the district court, the defendant referred to the Treaty of Guadalupe Hidalgo to point to the obscurity of who was and was not white, and therefore, eligible for citizenship rights:
It has been shown that Mexicans (and the term includes all Mexicans, without discrimination as to color) who remained in the ceded territory, and who failed to declare their intention within one year to remain Mexican citizens, became, by virtue of the stipulations of the treaty of February 2, 1848, citizens of the United States. Whether congress intended to include Mexicans in the expression “white male inhabitants,” as employed in the territorial acts above-mentioned, may admit of question.
Although the treaty specifically granted citizenship to Mexicans who remained in the ceded territory, defendants argued that Rodriguez maintained indigenous traits, thus making him unsuitable for citizenship due to his “racial inability”. Attorneys A.J. Evans and T.J. McMinn both argued that Rodriguez could be “classed with the copper-colored or red men. He has dark eyes, straight black hair, and high check bones.” After debating the racial ambiguity of Rodriguez, Judge Maxey concluded that he was not “an Indian” once Rodriguez testified that he knew nothing about indigenous practices or culture. Further, Maxey granted citizenship to Rodriguez arguing that the Treaty of Guadalupe-Hidalgo accorded citizenship rights to all Mexicans that remained in the relinquished territory, and that Rodriguez had, “practically illustrated and emphasized his attachment to the principles of the constitution,” and should be granted citizenship rights based upon these characteristics.
The ruling of In re Rodriguez became a landmark case for Mexicans, upholding their “white” status and giving them a naturalization exception that excluded Native Americans, Chinese, Japanese, and others. Yet the case itself was less meaningful in Arizona Territory, which would not achieve statehood until 1912. Rather, Mexicans in the territory would continue to struggle for representation in a territorial government that was largely controlled by mining interests.
[i] Article IX of the Treaty of Guadalupe-Hidalgo states:
Those who shall prefer to remain in the said territories may either retain the title and rights of Mexican citizens, or acquire those of citizens of the United States….those who shall remain…without having declared their intention to retain the character of Mexicans, shall be considered to have elected to become citizens of the United States.
This declaration presents unclear definitions of what it means to “retain the character of Mexicans” and marks the ensuing debates on racial categorization in the U.S. Southwest.