Specifically, Article 6 of the 1917 Treaty provided that those who did not declare
 within one year to retain their citizenship in Denmark "shall be held to have
 accepted citizenship in the United States." Immediately following this paragraph in
 Article 6 was another paragraph providing that "The civil rights and the political status
 of the inhabitants of the islands shall be determined by the Congress," subject to the
 stipulations of the Treaty.5

 The inhabitants hailed the Treaty of 1917, interpreting the provisions of Article 6
 as meaning a general extension of (1) United States citizenship, and (2) all rights in
 the United States Constitution. Washington administrators, the Congress, and the
 local Navy government all appeared to have shared these assumptions. In January
 1918, for example, Louis F. Post, Assistant Secretary of Labor, announced
 arrangements for meeting war-time "requirements for common labor" by the
 importation "of American citizens from Puerto Rico and the Virgin Islands.'6 Neither
 did the Treaty, however, grant United States citizenship to Virgin Islanders nor extend
 to them any rights under the United States Constitution.

 Two State Department communications effectively denied them United States
 citizenship. The first occurred during negotiations of the Treaty's provisions. Denmark
 had favored provisions that would specifically confer United States citizenship on the
 inhabitants, guarantee free trade between the Islands and the continental United
 States, and provide a plebiscite on the transfer. Secretary of State Lansing, in his
 June 2, 1916 telegram, rejected each of these Danish conditions. He replied that it
 would be impossible to confer citizenship on the inhabitants because this was a matter
 for Congress which had not yet accorded full citizenship to Puerto Ricans. "Danish
 West Indians, however, will be regarded as nationals of the United States and entitled
 to its full protection, and will receive every possible political liberty." As to free trade
 between the Islands and the continental United States, this also was within the
 province of Congress. Concerning a plebiscite in the Islands, Lansing wrote that the
 United States Government could not favor submitting "the question of transfer of the
 Islands to a vote of the inhabitants."7

 The second State Department communication denying that the Treaty of 1917
 had conferred United States citizenship on the Islanders was a letter of March 9, 1920
 from Acting Secretary of State Frank L. Polk to Senator Kenyon stating that the State
 Department was issuing passport to "inhabitants of the Virgin Islands entitled to the
 protection of the United States." The status of such persons was considered
 analogous to that of the inhabitants of the Philippine Islands under the Treaty of 1898
 and under the Act of Congress of 1902. "They have American nationality and are
 entitled to the protection of the government," explained Polk, "but have not civil and
 political status of citizens of the United States."8

 Richard W. Flourney, Jr., former acting chief of the Citizenship Bureau of the
State Department, remembered the arguments persuasive in 1920 in a 1933 interview
by Luther Evans, summarized by Evans as follows: