text: Under the Insular Cases of 1901, the Supreme Court ruled that unincorporated territories and insular possessions of the United States, which were not on a path toward statehood, had limited applicability of the U.S. Constitution. At the time, these included Guam, the Philippines, and Puerto Rico, acquired in 1898 at the end of the Spanish–American War. According to the decision, those born in insular possessions or unincorporated territories were not eligible for citizenship, though they were considered nationals and could hold a U.S. passport and gain diplomatic protection from the United States. Passage of the Expatriation Act of 1907 eliminated the uncertainty created in 1855, definitively stating that marriage solely determined all women's nationality. The law immediately revoked the nationality of married women, regardless of whether they were born in the United States or naturalized, if they were married to a non-citizen. It was retroactive and did not require a wife's consent, leaving many women unaware that they had lost their nationality.
  The federal Immigration Acts of 1921 and 1924 were passed by Congress to address the concern that white authority was declining. The 1921 Act, known as the Emergency Quota Act, restricted immigration from various countries. The limits applied to foreign husbands and children of U.S.-born women, but provided an exemption for foreign wives and children of birthright male nationals. In 1922, the Cable Act was passed, declaring that an American woman could not be denied the right to naturalize because she was married. It established procedures for women, who had previously lost their citizenship because of marriage, to repatriate as naturalized (not birthright) citizens. A wife's nationality depended on residence and her husband's eligibility to naturalize; if she lived abroad, her nationality on re-entry to U.S. territory was therefore subject to the restrictions of the Quota Act. However, because the Cable Act was worded to specifically state that "women citizens" who married ineligible foreigners lost their nationality, it did not apply to American Samoan women, as they were non-citizen nationals.