It would not be possible to take over a foreign area and completely ignore a large native population. This would, in turn, lead to the question of granting such people United States citizenship, which many Americans were reluctant to do, out of xenophobia and racism (Doc H). The Supreme Court decision in the case of Downes v. Bidwell (1901) echoed this, stating clearly that native populations of new colonies and territories were dealt with differently than Native Americans. This decision was given in one of the Insular Cases that defined the difference between incorporated and unincorporated territories. Incorporated territories were those that were granted civil rights, certain autonomy, and the capability to become states, such as Alaska and Hawaii, while unincorporated territories, such as Puerto Rico and the Philippines, were not granted the same rights as citizens and the degree of autonomy granted varied. This seems natural since Hawaii had been overrun by American businesses in the early 1890s, and although control of the islands was returned to their natives, there was clearly a strong American presence and interest there. In contrast, the Philippines, whose natives had revolted against American rule, were not granted this status of "statehood-pending.".
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Another difference between the old "Manifest Destiny" approach to the annexation of the West and imperialism was that in North American expansion, that is, the move west, it was clearly the intension of the United States to eventually introduce all of that territory as part of the country proper. That is, the result of western expansion for all new territories was statehood, whether sooner or later. This was not always the case in colonial expansion, and is closely tied to the question of what rights colonial natives would be granted. This also introduced perhaps the most controversial aspect of all: violation of the American Declaration of Independence.