and citizenship and controversy because of distinctions between jurisdictions of the United States. These differences have created what political scientist Charles R. Venator-Santiago has called "separate and unequal" statuses, and in an ambiguous liminal status. Relinquishing United States nationality United States citizens are allowed to give up their nationality and citizenship if the act is voluntary and intentional. Over time, 287 residents of Puerto Rico have formally renounced their nationality. Since 1990, the US State Department presumes no intention to give up nationality, even when a person has performed a potentially expatriating act. Renunciation requires making a formal declaration, which is sworn before a designated authority in the United States during a time of war, or abroad at any time to a consular officer; attending an interview and counseling session; payment of a fee; and signing requisite documents. In 1994, Juan Mari Brás flew to Venezuela and renounced his US nationality, in an attempt to rid himself from the colonialism inherent in US nationality for Puerto Rico. In 1995, he was issued a Certificate of Loss of Nationality by the State Department. In 1996, the Secretary of Justice issued clarification on the matter to the Governor of Puerto Rico confirming that nationality in a sovereign state is not the same as state or territorial citizenship. Further, because Puerto Rico falls under the sovereignty of the United States, renunciation of his nationality left him stateless and it would require a decision of the US Immigration and Naturalization Service, as to whether he could obtain a visa to remain in Puerto Rico after renunciation. In the US District Court for the District of Columbia a decision in Davis v. District Director (481 F. Supp. 1178, D.D.C., 1979) determined that renunciation of US nationality rendered the person an alien without right to remain in the country without a valid visa. The same district court upheld similar findings in Colón v. U.S. Department of State (2 F. Supp. 2d 43, D.D.C., 1998), ruling that US nationality cannot be renounced if it is the intent of a petitioner to reside in Puerto Rico and allege that they can do so because they have Puerto Rican citizenship. Shortly thereafter, because Mari Brás wished to remain in Puerto Rico, the State Department reversed its decision to accept his renunciation. Domestic citizenship Since 1900, with the establishment of the territorial legislature under the terms of the Foraker Act,