and development of the Political Code of Puerto Rico, domestic citizenship has been recognized and was later recognized in the Constitution of Puerto Rico. When women gained the right to vote in the United States in 1919, the Bureau of Insular Affairs confirmed that their new constitutional right did not extend to unincorporated territories. The US Supreme Court confirmed in the Insular Cases that extension of the franchise was bound by the terms in the Foraker Act. Puerto Rican suffragists and their supporters, led by women such as Isabel Andreu de Aguilar, Rosario Bellber, and Milagros Benet de Mewton, among others, introduced women's suffrage legislation in 1919, 1921, 1923, and 1927 without success. De Mewton sued the Electoral Board in 1924 for refusing to allow her to register, but the Supreme Court of Puerto Rico ruled against her on the grounds that the legislature had the authority to determine who were eligible voters in the island. Appealing to the United States legislature, suffragists pressed for federal legislation for the right to vote. When the US House introduced legislation in 1928, the Puerto Rican legislature agreed to review the issue. They passed a bill in 1929 to extend the franchise to women, limited to those who were literate. Universal suffrage was finally granted in Puerto Rico in 1936. The constitution adopted in 1952 provided citizens of the Commonwealth with a bill of rights consistent with the US Constitution. Acts of the Puerto Rican government must conform to federal requirements, but they are able to exercise self-governance in a manner similar to all states in the federal system. In 1997, during his quest to divest himself of US nationality, Mari Brás attempted to redefine Puerto Rican citizenship and have it recognized as nationality. In the case of Miriam J. Ramirez de Ferrer v. Juan Mari Brás (144 DPR 141, 1997) the Supreme Court of Puerto Rico reaffirmed that Puerto Rican citizenship existed, but that it existed in the context of a US nationality. The ruling confirmed that citizenship in the island was dependent on both US citizenship and residency in Puerto Rico. The day prior to the ruling, Puerto Rico's Political Code had been amended with similar language. Since the summer of 2007, the Puerto Rico State Department has developed a protocol to grant Puerto Rican citizenship certificates to Puerto Ricans. Certificates of Puerto Rican citizenship are issued on request by the