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SUFFOLK UNIVERSITY LAW REVIEW [Vol. L:587
creation of a new political entity without parallel in the history of the United
Sta tes.
In Sanchez Valle, the Court ratified and reaffirmed a judicial nonn that
began in the First Circuit with Mora v. Mejias,94 which was cited by the Court
in Calero-Toledo v. Pearson Yacht Leasing Co.95 In Calero-Toledo, the Court
sustained the application of a three-judge panel created to consider challenges
to a Puerto Rican law that violated the United States Constitution.96 The Court
reasoned that the federal law creating the three-judge panel was based on the
required deference to state laws, and Puerto Rico was entitled to similar
deference.97 Calero-Toledo was the first U.S. Supreme Court opinion that
validated Congress's efforts to democratize its relationship with Puerto Rico by
entering into a compact allowing for self-govemance under a separate
constitution.
The Court followed this opimon in Examining Board of Engineers,
Architects & Surveyors v. Flores de Otero,98 in which the Court first claimed
that Puerto Rico has "a relationship to the United States that has no parallel in
our history"-language subsequently quoted in Sanchez Valle.99 The issue
presented was whether a federal statute granting federal courts jurisdiction over
state civil rights violations can also apply to civil rights violations under the
laws of Puerto Rico.100 Analyzing in detail the events between 1950 and 1952,
and the Constitution of the Commonwealth of Puerto Rico, the Court concluded
that "Congress relinquished its control over the organization of the local affairs
of the island and granted Puerto Rico a measure of autonomy comparable to
that possessed by the States."1º1 Therefore, the law applied to Puerto Rico.102
Following the trend set in Calero-Toledoand Flores de Otero, in Rodriguez
v. Popular Democratic Party,103 the Court upheld Puerto Rico's political
structure when the Popular Democratic Party challenged a statute regarding a
legislator's posthumous replacement.P" The Court concluded that Puerto Rico
deserves "substantial deference" given that "Puerto Rico, like a state, is an
autonomous política! entíty, 'sovereign over matters not ruled by the
94. 206F.2d377(lstCir.1953).
95. 416 u.s. 663, 672-73 (1974).
96. See id. at 675- 76 (equating Puerto Rico's enactments to state statutes for purposes of three-judge
panels).
97. See id. at 670-76 (recognizing need for respect with regards to territorial enactments).
98. 426 u.s. 572 (1976).
99. See id. at 596; see a/so Puerto Rico v. Sanchez Valle, 136 S. Ct. 1863, 1876 (2016) (discussing Puerto
Rico 's relationship with United States).
l OO. See Flores de Otero, 426 U.S. at 574-75 (repbrasing issue to whether Puerto Rico considered state for
civil rights purposes); see a/so 42 U.S.C. § 1983 (2012) (prohibiting state law from infringing on civil rights).
l O l. See Flores de Otero, 426 U.S. at 597 (describing Puerto Rico's autonomy from Congress).
102. See id. (detennining law applies to both territories and states).
103. 457 u.s. 1 (1982).
l 04. See id. at 3-4, 12 (validating Puerto Rico's process for fitting legislative vacancies).
creation of a new political entity without parallel in the history of the United
Sta tes.
In Sanchez Valle, the Court ratified and reaffirmed a judicial nonn that
began in the First Circuit with Mora v. Mejias,94 which was cited by the Court
in Calero-Toledo v. Pearson Yacht Leasing Co.95 In Calero-Toledo, the Court
sustained the application of a three-judge panel created to consider challenges
to a Puerto Rican law that violated the United States Constitution.96 The Court
reasoned that the federal law creating the three-judge panel was based on the
required deference to state laws, and Puerto Rico was entitled to similar
deference.97 Calero-Toledo was the first U.S. Supreme Court opinion that
validated Congress's efforts to democratize its relationship with Puerto Rico by
entering into a compact allowing for self-govemance under a separate
constitution.
The Court followed this opimon in Examining Board of Engineers,
Architects & Surveyors v. Flores de Otero,98 in which the Court first claimed
that Puerto Rico has "a relationship to the United States that has no parallel in
our history"-language subsequently quoted in Sanchez Valle.99 The issue
presented was whether a federal statute granting federal courts jurisdiction over
state civil rights violations can also apply to civil rights violations under the
laws of Puerto Rico.100 Analyzing in detail the events between 1950 and 1952,
and the Constitution of the Commonwealth of Puerto Rico, the Court concluded
that "Congress relinquished its control over the organization of the local affairs
of the island and granted Puerto Rico a measure of autonomy comparable to
that possessed by the States."1º1 Therefore, the law applied to Puerto Rico.102
Following the trend set in Calero-Toledoand Flores de Otero, in Rodriguez
v. Popular Democratic Party,103 the Court upheld Puerto Rico's political
structure when the Popular Democratic Party challenged a statute regarding a
legislator's posthumous replacement.P" The Court concluded that Puerto Rico
deserves "substantial deference" given that "Puerto Rico, like a state, is an
autonomous política! entíty, 'sovereign over matters not ruled by the
94. 206F.2d377(lstCir.1953).
95. 416 u.s. 663, 672-73 (1974).
96. See id. at 675- 76 (equating Puerto Rico's enactments to state statutes for purposes of three-judge
panels).
97. See id. at 670-76 (recognizing need for respect with regards to territorial enactments).
98. 426 u.s. 572 (1976).
99. See id. at 596; see a/so Puerto Rico v. Sanchez Valle, 136 S. Ct. 1863, 1876 (2016) (discussing Puerto
Rico 's relationship with United States).
l OO. See Flores de Otero, 426 U.S. at 574-75 (repbrasing issue to whether Puerto Rico considered state for
civil rights purposes); see a/so 42 U.S.C. § 1983 (2012) (prohibiting state law from infringing on civil rights).
l O l. See Flores de Otero, 426 U.S. at 597 (describing Puerto Rico's autonomy from Congress).
102. See id. (detennining law applies to both territories and states).
103. 457 u.s. 1 (1982).
l 04. See id. at 3-4, 12 (validating Puerto Rico's process for fitting legislative vacancies).
