Balzac v. Porto Rico, 258 U.S. 298 (1922)

Balzac v. Porto Rico (1922) is a landmark Insular Cases decision in which the Supreme Court held that the Sixth Amendment right to a jury trial does not apply in Puerto Rico because it is an unincorporated territory.

Jesús M. Balzac, the editor of a newspaper in Arecibo, Puerto Rico, was convicted of criminal libel in a trial without a jury. He appealed, arguing that the Jones Act of 1917 — which had granted U.S. citizenship to all Puerto Ricans — automatically extended full constitutional rights to Puerto Rico.

Chief Justice William Howard Taft wrote for a unanimous Court that granting U.S. citizenship to Puerto Ricans did not make Puerto Rico an incorporated territory: "The jury system needs citizens trained to the exercise of the responsibilities of jurors... Congress has thought that a people like the Filipinos or the Porto Ricans, trained to a complete judicial system which knows no juries... would be harmed by being forced to adopt it."

The decision established that U.S. citizenship and constitutional rights are separable in the territories — that Congress can grant citizenship without extending the full Bill of Rights. This remains the operative legal framework today: Puerto Ricans are U.S. citizens who do not enjoy the same constitutional protections as citizens on the mainland.