evidence: Navassa: Property, Sovereignty, and the Law of the Territories abstract. The United States acquired its first overseas territory—Navassa Island, near Haiti—by conceptualizing it as a kind of property to be owned, rather than a piece of sovereign territory to be governed. The story of Navassa shows how competing conceptions of property and sovereignty are an important and underappreciated part of the law of the territories—a story that continued fifty years later in the Insular Cases, which described Puerto Rico as "belonging to" but not "part of" the United States. [...] The story of Navassa is thus in part a story of a colonial power using the concepts of property and sovereignty to its advantage, and thereby relegating the island—like Puerto Rico and the other unincorporated territories—to the status of a "disembodied shade."22 But even as the dust was settling on the Insular Cases and the United States was fighting a war over the status of its largest territory (the Philippines), U.S. legal scholars were exploring—and complicating—the conceptual relationship between property and sovereignty.23 That ongoing exploration and the law of the territories have much to learn from each other.