Territories of the United States
Territories of the United States are sub-national administrative divisions overseen by the U.S. federal government. The various U.S. territories differ from the U.S. states and Native American tribes in that they are not sovereign entities. In contrast, each state has a sovereignty separate from that of the federal government and each federally recognized Native American tribe possesses limited tribal sovereignty as a "dependent sovereign nation". Territories are classified by incorporation and whether they have an "organized" government through an organic act passed by the Congress. U.S. territories are under U.S. sovereignty and, consequently, may  be treated as part of the United States "proper" in some ways and not others (i.e., territories belong to, but are not considered to be a part of, the United States). Unincorporated territories in particular are not considered to be integral parts of the United States, and the Constitution of the United States applies only partially in those territories. The U.S. currently administers three territories in the Caribbean Sea and eleven in the Pacific Ocean. Five territories (American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands) are permanently inhabited, unincorporated territories; the other nine are  small islands, atolls, and reefs with no native (or permanent) population. Of the nine, only one is classified as an incorporated territory (Palmyra Atoll). Two additional territories (Bajo Nuevo Bank and Serranilla Bank) are claimed by the United States but administered by Colombia. Historically, territories were created to administer newly acquired land, and most eventually attained statehood. Others, such as the Philippines, the Federated States of Micronesia, the Marshall Islands, and Palau, later became independent. Many organized, incorporated territories existed from 1789 to 1959. The first were the Northwest and Southwest territories and the last were the Alaska and Hawaii  territories. Thirty-one territories (or parts of territories) became states. In the process, some less-populous areas of a territory were orphaned from it after a statehood referendum. When a portion of the Missouri Territory became the state of Missouri, the remainder of the territory (the present-day states of Iowa, Nebraska, South Dakota and North Dakota, most of Kansas, Wyoming, and Montana, and parts of Colorado and Minnesota) became an unorganized territory. Politically and economically, the territories are underdeveloped. Residents of U.S. territories cannot vote in U.S. Presidential elections, and they have only non-voting representation in the  U.S. Congress. Territorial telecommunications and other infrastructure is generally inferior to that of the continental United States and Hawaii, and some territories' Internet speed was found to be slower than the least developed countries in Eastern Europe. Poverty rates are higher in the territories than in the states. Organized vs. unorganized territories. Definition. Organized territories are lands under federal sovereignty (but not part of any state) which were given a measure of self-governance by Congress through an organic act subject to the Congress's plenary powers under the territorial clause of the Constitution's Article Four, section 3. Former . The term "unorganized" was historically applied either to a newly acquired region not yet constituted as an organized incorporated territory (e.g. the Louisiana Purchase prior to the establishment of Orleans Territory and the District of Louisiana), or to a region previously part of an organized incorporated territory left "unorganized" after part of it had been organized and achieved the requirements for statehood (e.g. a large portion of Missouri Territory became unorganized territory for several years after its southeastern section became the state of Missouri). Regions that have been admitted as states by the United States Constitution in addition to the  original thirteen were (most often), prior to admission, territories or parts of territories of this kind. As the United States grew, the most populous parts of the organized territory would achieve statehood. Some territories existed only a short time before becoming states, while others remained territories for decades. The shortest-lived was Alabama Territory at two years, while New Mexico Territory and Hawaii Territory both lasted more than 50 years. Of the current 50 U.S. states, 31 were at one time or another part of an organized, incorporated U.S. territory. In addition to the original 13, six subsequent states never  were. Kentucky, Maine, and West Virginia were each set off from already existing states. Texas and Vermont both entered the Union after having been sovereign states (only "de facto" sovereignty in Vermont's case, as the region was claimed by New York). California was set off from unorganized land ceded to the United States by Mexico in 1848 at the end of the Mexican–American War. Current status. All of the five major U.S. territories are permanently inhabited and have constitutions, locally elected territorial legislatures and executives, and some degree of political autonomy. Four of the five are "organized", but  American Samoa is technically "unorganized". All of the U.S. territories without permanent non-military populations are unorganized. Federal administration. The Office of Insular Affairs coordinates federal administration of the U.S. territories and freely associated states, except for Puerto Rico. On March 3, 1849, the last day of the 30th Congress, a bill was passed to create the U.S. Department of the Interior to take charge of the internal affairs of "United States territory". The Interior Department has a wide range of responsibilities (which include the regulation of territorial governments, the basic responsibilities for public lands, and other various duties). In  contrast to similarly named Departments in other countries, the United States Department of the Interior is not responsible for local government or for civil administration except in the cases of Indian reservations, through the Bureau of Indian Affairs (BIA), and island dependencies administered by the Office of Insular Affairs. Permanently inhabited territories. The U.S. has five permanently inhabited territories: Puerto Rico and the U.S. Virgin Islands in the Caribbean Sea, Guam and the Northern Mariana Islands in the North Pacific Ocean, and American Samoa in the South Pacific Ocean. American Samoa is in the Southern Hemisphere, while the other four  are in the Northern Hemisphere. In 2020, their combined population was about 3.62 million, over 90% of which is accounted for by Puerto Rico alone. People born in Puerto Rico, the U.S. Virgin Islands, Guam and the Northern Mariana Islands acquire U.S. citizenship by birth, and foreign nationals residing there may apply for U.S. citizenship by naturalization. People born in American Samoa acquire U.S. nationality but not U.S. citizenship by birth if they do not have a U.S. citizen parent. U.S. nationals without U.S. citizenship may hold U.S. passports and reside in any part of the United States without restriction . However, to become U.S. citizens they must apply for naturalization, like foreigners, and may only do so while residing in parts of the United States other than American Samoa. Foreign nationals residing in American Samoa cannot apply for U.S. citizenship or U.S. nationality at all. Each territory is self-governing with three branches of government, including a locally elected governor and a territorial legislature. Each territory elects a non-voting member (a non-voting resident commissioner in the case of Puerto Rico) to the U.S. House of Representatives. They "possess the same powers as other members of the House , except that they may not vote [on the floor] when the House is meeting as the House of Representatives"; they debate, are assigned offices and staff funding, and nominate constituents from their territories to the Army, Naval, Air Force and Merchant Marine academies. They can vote in their appointed House committees on all legislation presented to the House, they are included in their party count for each committee, and they are equal to senators on conference committees. Depending on the Congress, they may also vote on the floor in the House Committee of the Whole. As of the 117th Congress  (January 3, 2021January 3, 2023) the territories are represented by Aumua Amata Radewagen (R) of American Samoa, Michael San Nicholas (D) of Guam, Gregorio Sablan (D) of Northern Mariana Islands, Jenniffer González-Colón (R-PNP) of Puerto Rico and Stacey Plaskett (D) of U.S. Virgin Islands. The District of Columbia's delegate is Eleanor Holmes Norton (D); like the district, the territories have no vote in Congress and no representation in the Senate. Additionally, the Cherokee Nation has delegate-elect Kimberly Teehee, who has not been seated by Congress. Every four years, U.S. political parties nominate presidential candidates at conventions  which include delegates from the territories. U.S. citizens living in the territories can vote for presidential candidates in these primary elections but not in the general election. The territorial capitals are Pago Pago (American Samoa), Hagåtña (Guam), Saipan (Northern Mariana Islands), San Juan (Puerto Rico) and Charlotte Amalie (U.S. Virgin Islands). Their governors are Lemanu Peleti Mauga (American Samoa), Lou Leon Guerrero (Guam), Ralph Torres (Northern Mariana Islands), Pedro Pierluisi (Puerto Rico) and Albert Bryan (U.S. Virgin Islands). Among the inhabited territories, Supplemental Security Income (SSI) is available only in the Northern Mariana Islands; however in 2019 a U.S. judge  ruled that the federal government's denial of SSI benefits to residents of Puerto Rico is unconstitutional. This ruling was later overturned by the U.S. Supreme Court, allowing for the exclusion of territories from such programs. In the decision, the court explained that the exemption of island residents from most federal income taxes provides a "rational basis" for their exclusion from eligibility for SSI payments. American Samoa is the only U.S. territory with its own immigration system (a system separate from the United States immigration system). American Samoa also has a communal land system in which ninety percent of the  land is communally owned; ownership is based on Samoan ancestry. Statistics. Except for Guam, the inhabited territories lost population in 2020. Although the territories have higher poverty rates than the mainland U.S., they have high Human Development Indexes. Four of the five territories have another official language, in addition to English. The territories do not have administrative counties. The U.S. Census Bureau counts Puerto Rico's 78 municipalities, the U.S. Virgin Islands' three main islands, all of Guam, the Northern Mariana Islands' four municipalities, and American Samoa's three districts and two atolls as county equivalents. The Census Bureau also  counts each of the U.S. Minor Outlying Islands as county equivalents. For statistical purposes, the U.S. Census Bureau has a defined area called the "Island Areas" which consists of American Samoa, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands (every major territory except Puerto Rico). The U.S. Census Bureau often treats Puerto Rico as its own entity or groups it with the states and D.C. (for example, Puerto Rico has a QuickFacts page just like the states and D.C.) Puerto Rico data is collected annually in American Community Survey estimates (just like the states), but data for the  other territories is collected only once every ten years. Governments and legislatures. The five major inhabited territories contain the following governments and legislatures: Political party status. The following is the political party status of the governments of the U.S. territories following completion of the 2020 United States elections. Instances where local and national party affiliation differs, the national affiliation is listed second. Guam and the U.S. Virgin Islands have unicameral territorial legislatures. Courts. Each of the five major territories has its own local court system: Of the five major territories, only Puerto Rico has an Article III federal district court  (i.e., equivalent to the courts in the fifty states); it became an Article III court in 1966. This means that, unlike other U.S. territories, federal judges in Puerto Rico have life tenure. Federal courts in Guam, the Northern Mariana Islands and the U.S. Virgin Islands are Article IV territorial courts. The following is a list of federal territorial courts, plus Puerto Rico's court: American Samoa does not have a federal territorial court, and so federal matters in American Samoa are sent to either the District court of Hawaii or the District court of the District of Columbia. American Samoa  is the only permanently inhabited region of the United States with no federal court. Demographics. While the U.S. mainland is majority non-Hispanic White, this is not the case for the U.S. territories. In 2010, American Samoa's population was 92.6% Pacific Islander (including 88.9% Samoan); Guam's population was 49.3% Pacific Islander (including 37.3% Chamorro) and 32.2% Asian (including 26.3% Filipino); the population of the Northern Mariana Islands was 34.9% Pacific Islander and 49.9% Asian; and the population of the U.S. Virgin Islands was 76.0% African American. In 2019, Puerto Rico's population was 98.9% Hispanic or Latino, 67.4 % white, and 0.8% non-Hispanic white. Throughout the 2010s, the U.S. territories (overall) lost population. The combined population of the five inhabited territories was 4,100,594 in 2010, and 3,569,284 in 2020. The U.S. territories have high religiosity rates—American Samoa has the highest religiosity rate in the United States (99.3% religious and 98.3% Christian). Economies. The economies of the U.S. territories vary from Puerto Rico, which has a GDP of $104.989 billion in 2019, to American Samoa, which has a GDP of $636 million in 2018. In 2018, Puerto Rico exported about $18 billion in goods, with  the Netherlands as the largest destination. Guam's GDP shrank by 0.3% in 2018, the GDP of the Northern Mariana Islands shrank by 19.6% in 2018, Puerto Rico's GDP grew by 1.18% in 2019, and the U.S. Virgin Islands' GDP grew by 1.5% in 2018. In 2017, American Samoa's GDP shrank by 5.8%, but then grew by 2.2% in 2018. American Samoa has the lowest per capita income in the United States—it has a per capita income comparable to that of Botswana. In 2010, American Samoa's per capita income was $6,311. As of 2010, the  Manu'a District in American Samoa had a per capita income of $5,441, the lowest of any county or county-equivalent in the United States. In 2018, Puerto Rico had a median household income of $20,166 (lower than the median household income of any state). Also in 2018, Comerío Municipality, Puerto Rico had a median household income of $12,812 (the lowest median household income of any populated county or county-equivalent in the U.S.) Guam has much higher incomes (Guam had a median household income of $48,274 in 2010.) Minor Outlying Islands. The United States Minor Outlying  Islands are small islands, atolls and reefs. Baker Island, Howland Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Atoll, Palmyra Atoll, and Wake Island are in the Pacific Ocean, and Navassa Island is in the Caribbean Sea. The additional disputed territories of "Bajo Nuevo Bank" and "Serranilla Bank" are also located in the Caribbean Sea. Palmyra Atoll (formally known as the United States Territory of Palmyra Island) is the only incorporated territory, a status it has maintained since Hawaii became a state in 1959. All are uninhabited except for Midway Atoll, whose approximately 40 inhabitants are employees of the U.S.  Fish and Wildlife Service and their services provider; Palmyra Atoll, whose population varies from four to 20 Nature Conservancy and Fish and Wildlife staff and researchers; and Wake Island, which has a population of about 100 military personnel and civilian employees. The two-letter abbreviation for the islands collectively is "UM". The status of several islands is disputed. Navassa Island is disputed by Haiti, Wake Island is disputed by the Marshall Islands, Swains Island (a part of American Samoa) is disputed by Tokelau, and "Bajo Nuevo Bank" and "Serranilla Bank" (both administered by Colombia) are disputed by Colombia, Jamaica, Honduras , and Nicaragua. Disputed. The following two territories are claimed by multiple countries (including the United States), and are not included in . However, they are sometimes grouped with the U.S. Minor Outlying Islands. According to the GAO, "the United States conducts maritime law enforcement operations in and around Serranilla Bank and Bajo Nuevo [Bank] consistent with U.S. sovereignty claims." Incorporated vs. unincorporated territories. Pursuant to a series of Supreme Court rulings, Congress decides whether a territory is incorporated or unincorporated. The U.S. Constitution applies to each incorporated territory (including its local government and inhabitants) as it applies to the local governments  and residents of a state. Incorporated territories are considered to be integral parts of the U.S., rather than possessions. In unincorporated territories, "fundamental rights apply as a matter of law, but other constitutional rights are not available", raising concerns about how citizens in these territories can influence politics in the United States. Selected constitutional provisions apply, depending on congressional acts and judicial rulings according to U.S. constitutional practice, local tradition, and law. As a result, these territories are often considered colonies of the United States. All modern inhabited territories under the control of the federal government can be considered as  part of the "United States" for purposes of law as defined in specific legislation. However, the judicial term "unincorporated" was coined to legitimize the late-19th-century territorial acquisitions without citizenship and their administration without constitutional protections temporarily until Congress made other provisions. The case law allowed Congress to impose discriminatory tax regimes with the effect of a protective tariff upon territorial regions which were not domestic states. In 2022, the United States Supreme Court held that the territorial clause of the constitution allowed wide congressional latitude in mandating "reasonable" tax and benefit schemes in Puerto Rico and the other territories , which are different from the states, but did not address the incorporated/unincorporated distinction. In a concurrence, one of the justices opined that it was time to overrule the incorporation doctrine, as wrongly decided and founded in racism. Insular Cases. The U.S. Supreme Court, in its 1901–1905 Insular Cases, ruled that the Constitution extended (i.e., of its own force) to the continental territories. The Court also established the doctrine of territorial incorporation, in which the Constitution applies fully to incorporated territories (such as the then-territories of Alaska and Hawaii) and partially in the unincorporated territories of Puerto Rico, Guam  and, at the time, the Philippines (which is no longer a U.S. territory). In the 1901 Supreme Court case "Downes v. Bidwell", the Court said that the U.S. Constitution did not fully apply in unincorporated territories because they were inhabited by "alien races". The U.S. had no unincorporated territories (also known as overseas possessions or insular areas) until 1856. Congress enacted the Guano Islands Act that year, authorizing the president to take possession of unclaimed islands to mine guano. The U.S. has taken control of (and claimed rights on) many islands and atolls, especially in the Caribbean Sea and the  Pacific Ocean, under this law; most have been abandoned. It also has acquired territories since 1856 under other circumstances, such as under the Treaty of Paris (1898) which ended the Spanish–American War. The Supreme Court considered the constitutional position of these unincorporated territories in 1922 in "Balzac v. People of Porto Rico", and said the following about a U.S. court in Puerto Rico: In "Glidden Company v. Zdanok", the Court cited "Balzac" and said about courts in unincorporated territories: "Upon like considerations, Article III has been viewed as inapplicable to courts created in unincorporated territories outside the mainland... and  to the consular courts established by concessions from foreign countries..." The judiciary determined that incorporation involves express declaration or an implication strong enough to exclude any other view, raising questions about Puerto Rico's status. In 1966, Congress made the United States District Court for the District of Puerto Rico an Article III district court. This (the only district court in a U.S. territory) sets Puerto Rico apart judicially from the other unincorporated territories, and U.S. district judge Gustavo Gelpi express the opinion that Puerto Rico is no longer unincorporated: In "Balzac", the Court defined "implied": On June 5, 2015 , the U.S. Court of Appeals for the District of Columbia ruled 3–0 in "Tuaua v. United States" to deny birthright citizenship to American Samoans, ruling that the guarantee of such citizenship to citizens in the Fourteenth Amendment does not apply to unincorporated U.S. territories. In 2016 the U.S. Supreme Court declined to review the appellate court's decision. In 2018, the United States Court of Appeals for the 7th Circuit upheld the District Court decision in "Segovia v. United States", which ruled that former Illinois residents living in Puerto Rico, Guam, and the U.S. Virgin Islands did not qualify to  cast overseas ballots according to their last registered address on the U.S. mainland. (Residents of the Northern Marianas and American Samoa, however, were still allowed to cast such ballots.) In October 2018, the U.S. Supreme Court declined to review the 7th Circuit's decision. In analyzing the Insular Cases, Christina Duffy Ponsa of the New York Times said the following: "To be an unincorporated territory is to be caught in limbo: although unquestionably subject to American sovereignty, they are not considered part of the United States for certain purposes but not others. Whether they are part of the United States  for purposes of the Citizenship Clause remains unresolved." Supreme Court decisions about current territories. The 2016 Supreme Court case "Puerto Rico v. Sanchez Valle" ruled that territories do not have their own sovereignty. That year, the Supreme Court declined to rule on a lower-court ruling in "Tuaua v. United States" that American Samoans are not U.S. citizens at birth. Supreme Court decisions about former territories. In "Rassmussen v. U.S.", the Supreme Court quoted from Article III of the 1867 treaty for the purchase of Alaska: Alaska Territory. "Rassmussen" arose from a criminal conviction by a six-person jury in  Alaska under federal law. The court held that Alaska had been incorporated into the U.S. in the treaty of cession with Russia, and the congressional implication was strong enough to exclude any other view: Concurring justice Henry Brown agreed: Florida Territory. In "Dorr v. U.S.", the court quoted Chief Justice John Marshall from an earlier case: In "Downes v. Bidwell", the court said: "The same construction was adhered to in the treaty with Spain for the purchase of Florida... the 6th article of which provided that the inhabitants should 'be incorporated into the Union of the United States, as soon  as may be consistent with the principles of the Federal Constitution'." Southwest Territory. Justice Brown first mentioned incorporation in "Downes": Louisiana Territory. In "Downes", the court said: Modern Puerto Rico. Scholars agreed as of 2009 in the "Boston College Law Review", "Regardless of how Puerto Rico looked in 1901 when the Insular Cases were decided, or in 1922, today, Puerto Rico seems to be the paradigm of an incorporated territory as modern jurisprudence understands that legal term of art". In November 2008 a district court judge ruled that a sequence of prior Congressional actions had the cumulative effect of changing  Puerto Rico's status to incorporated. The United States Supreme Court, in 2021, held that the territorial clause of the constitution allowed wide congressional latitude in mandating "reasonable" tax and benefit schemes in Puerto Rico and the other territories that are different from the states, but did not address the incorporated/unincorporated distinction. In a concurrence, one of the justices opined that it was time to overrule the "Insular Cases" and the incorporation doctrine, as wrongly decided. Former territories and administered areas. Formerly unorganized territories. At various times during the 19th century, large parts of the Great Plains were unorganized  territory. After the Louisiana Purchase from France in 1803, the entire region was part of the Louisiana Territory until 1812 and the Missouri Territory until 1821. In 1821 the Missouri Compromise created the State of Missouri from the territory, and the rest of the region was left unorganized. The Kansas–Nebraska Act of 1854 created the Kansas and Nebraska Territories, bringing organized government to the region once again. The creation of Kansas and Nebraska left the Indian Territory as the only unorganized territory in the Great Plains. In 1858, the western part of the Minnesota Territory became unorganized when it  was not included in the new state of Minnesota; this area was organized in 1861 as part of the Dakota Territory. On May 2, 1890, the western half of the Indian Territory was organized as Oklahoma. The remainder was incorporated into the State of Oklahoma upon its admission to the union in 1907. Alaska was an unorganized territory between its acquisition from Russia in 1867 and the creation of Alaska Territory in 1912. Hawaii was as well from the time of its annexation by the U.S. in 1898 until organized as Hawaii Territory in 1900. Flora and fauna. The territories  of the United States have many plant and animal species found nowhere else in the United States. All U.S. territories have tropical climates and ecosystems. Forests. The USDA says the following about the U.S. territories (plus Hawaii): Forests in the U.S. territories are vulnerable to invasive species and new housing developments. El Yunque National Forest in Puerto Rico is the only tropical rain forest in the United States National Forest system. American Samoa has 80.84% forest cover and the Northern Mariana Islands has 80.37% forest cover—these are among the highest forest cover percentages in the United States (only Maine  and New Hampshire are higher). Birds. U.S. territories have many bird species that are endemic (not found in any other location). Introduction of the invasive brown tree snake has harmed Guam's native bird population—nine of twelve endemic species have become extinct, and the territorial bird (the Guam rail) is extinct in the wild. Puerto Rico has several endemic bird species, such as the critically endangered Puerto Rican parrot, the Puerto Rican flycatcher, and the Puerto Rican spindalis. The Northern Mariana Islands has the Mariana swiftlet, Mariana crow, Tinian monarch and golden white-eye (all endemic). Birds found in  American Samoa include the many-colored fruit dove, the blue-crowned lorikeet, and the Samoan starling. The Wake Island rail (now extinct) was endemic to Wake Island, and the Laysan duck is endemic to Midway Atoll and the Northwest Hawaiian Islands. Palmyra Atoll has the second-largest red-footed booby colony in the world, and Midway Atoll has the largest breeding colony of Laysan albatross in the world. The American Birding Association currently excludes the U.S. territories from their "ABA Area" checklist. Other animals. American Samoa has several reptile species, such as the Pacific boa (on the island of Ta‘ū ) and Pacific slender-toed gecko. American Samoa has only a few mammal species, such as the Pacific (Polynesian) sheath-tailed bat, as well as oceanic mammals such as the Humpback whale. Guam and the Northern Mariana Islands also have a small number of mammals, such as the Mariana fruit bat; oceanic mammals include Fraser's dolphin and the Sperm whale. The fauna of Puerto Rico includes the common coquí (frog), while the fauna of the U.S. Virgin Islands includes species found in Virgin Islands National Park (including 302 species of fish). American Samoa has a location called Turtle and Shark  which is important in Samoan culture and mythology. Protected areas. There are two National Parks in the U.S. territories: the National Park of American Samoa, and Virgin Islands National Park. The National Park Service also manages War in the Pacific National Historical Park on Guam. There are also National Natural Landmarks, National Wildlife Refuges (such as Guam National Wildlife Refuge), El Yunque National Forest in Puerto Rico, and the Pacific Remote Islands Marine National Monument (which includes the U.S. Minor Outlying Islands). Public image. In "The Not-Quite States of America", his book about the U.S. territories, essayist Doug Mack  said: Organizations such as Facebook view U.S. territories as not being part of the United States—instead, they are viewed as equivalent to foreign countries. In response to Facebook's view, former Guam representative Madeleine Bordallo said, "It is an injustice that Americans living in the U.S. territories are not treated as other Americans living in the states. [...] Treating residents of Guam and other U.S. territories as living outside the United States and excluding them from programs perpetuates misconceptions and injustices that have long had a negative impact on our communities". Representative Stephanie Murphy of Florida said about a 2018  bill to make Puerto Rico the 51st state, "The hard truth is that Puerto Rico's lack of political power allows Washington to treat Puerto Rico like an afterthought." According to Governor of Puerto Rico Ricardo Rosselló, "Because we don't have political power, because we don't have representatives, [no] senators, no vote for president, we are treated as an afterthought." Rosselló called Puerto Rico the "oldest, most populous colony in the world". Rosselló and others have referred to the U.S. territories as American "colonies". David Vine of "The Washington Post" said the following: "The people of [the U.S.  territories] are all too accustomed to being forgotten except in times of crisis. But being forgotten is not the worst of their problems. They are trapped in a state of third-class citizenship, unable to access full democratic rights because politicians have long favored the military's freedom of operation over protecting the freedoms of certain U.S. citizens." In his article "How the U.S. Has Hidden Its Empire", Daniel Immerwahr of "The Guardian" writes, "The confusion and shoulder-shrugging indifference that mainlanders displayed [toward territories] at the time of Pearl Harbor hasn't changed much at all. [...] [Maps of the  contiguous U.S.] give [mainlanders] a truncated view of their own history, one that excludes part of their country." The 2020 U.S. Census excludes non-citizen U.S. nationals in American Samoa—in response to this, Mark Stern of Slate.com said, "The Census Bureau's total exclusion of American Samoans provides a pertinent reminder that, until the courts step in, the federal government will continue to treat these Americans with startling indifference."