evidence: 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. [...] Joseph Blocher & Mitu Gulati, Navassa: Property, Sovereignty, and the Law of the Territories, 131 Yale Law Journal 2390-2448 (2022)