First Circuit: Colon-Marrero v. Garcia-Velez

Elections, Puerto Rico, Statutory Construction

Congress did not intend that Puerto Rico be considered a "state" under voting law.

Dis-inclusion of Puerto Rico does not burden the voting right, and the principle survives rational basis.

Puerto Rico is considered a state under a second statute barring removal from voter rolls until after two missed elections.

Second statute creates a private right presumptively actionable under S1983.

http://media.ca1.uscourts.gov/pdf.opinions/15-1356P-01A.pdf