Put a Sticker on It: Civil Rights, Bilingual Voting, and Puerto Ricans in Philadelphia in the 1970s

Put a Sticker on It: Civil Rights, Bilingual Voting and Puerto Ricans in Philadelphia in the 1970sARIEL ARNAU

The author ([email protected]), born and raised in the Bronx, has been living in Philadelphia since the mid-1990s. He received his BA and MA in History from Temple University. After working ten years in the nonprofit sector, he returned to teach Latino Studies and Latin American history at his alma mater. Ariel is a PhD student at the CUNY Graduate Center. He is an avid fan of the New York Yankees, comic books, and science fiction.

ABSTRACT

This article details the process, result, and impact of the Arroyo v Tucker bilingual elec-tion lawsuit in Philadelphia in 1973. After this litigation, bilingual elections were required by law, but their implementation left something to be desired. This lawsuit is placed within the context of the “long” Civil Rights Movement and argues that Puerto Ricans were active in the formation of Civil Rights legislation and not merely its benefi ciaries. While the “long” movement has been debated by Civil Rights historians, a “broad” interpretive framework allows for the inclusion of other marginalized groups as active participants in the movement. [Key Words: Puerto Ricans, Philadelphia, Civil Rights, Bilingualism, Elections]

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Judge Joseph S. Lord III sat in his office listening intently to the attorney for the

defendant Michael Minkin. “Your Honor,” declared Minkin, “setting up Spanish signs

and materials at every election site would take too much time and be too costly for

the Commonwealth of Pennsylvania and the City of Philadelphia. The election is only a month away.” “Too long?” Lord responded. “How hard is it to put a sticker on it? Shall we time it then?” Lord took out a blank 8 ½ by 11” sheet of paper from his worn wooden desk. “Let us assume for a moment that this paper is a sign in Spanish with election instructions on it. Could you please tape it to the front of my office door? I want to see how long that would take.” The attorneys representing the plaintiffs, Nelson Diaz and Herbert Teitelbaum, sat back in their chairs with wry smiles on their faces (Diaz 2013: 11).

This meeting and the seemingly innocuous request to tape a piece of paper to a door in October 1973 was the first salvo in a legal battle that lasted for three years. Diaz and Teitelbaum were an unlikely pair. Diaz, a relatively young and inexperienced Puerto Rican lawyer born in East Harlem and fresh out of Temple University’s Beasley School of Law, had lived in Philadelphia long enough to make a number of connections at the grassroots-level with the local Puerto Rican community. Teitelbaum, a Jewish attorney and the Legal Director for the Puerto Rican Legal Defense and Education Fund (PRLDEF), was a seasoned civil rights litigator and life-long New Yorker. These two very different men came together to advocate on behalf of two Puerto Rican women living in Philadelphia, who simply wanted to exercise their right to vote. The obstacle that hindered Peggy Arroyo and Petra Gonzalez was that they did not speak English. At issue in this case, Arroyo v. Tucker, was the right of Puerto Ricans in Philadelphia to have access to bilingual ballots and other voting materials. Diaz and Teitelbaum at first sought compliance from officials at both the state and municipal levels to provide Spanish translators and bilingual materials at any polling place where Spanish-dominant Puerto Ricans were likely to vote in Philadelphia. The lack of forward movement on this issue motivated these two lawyers in October 1973 to file a temporary injunction to halt the upcoming November elections in Philadelphia until their grievance was resolved. Although the November elections were allowed to continue, the two sides in this case negotiated until a final order and court opinion on this lawsuit were issued in March 1974. Despite the agreement

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and the court order, the implementation of bilingual elections remained unresolved for another year.

While a series of negotiations and legal affidavits might not be the stuff of legend and lore, the legal proceedings in this lawsuit are critical to enhancing our understanding not only of how a disenfranchised community advocated and organized on its own behalf, but also in broadening our understanding of the Civil Rights Movement in American history. While historians urged continued study of racial and ethnic movements for social justice at the local level, not enough work has been done about the Puerto Rican diaspora and its contribution to the larger struggle for equality in American history beyond the African-American context. By examining the particulars of the Arroyo v. Tucker lawsuit we can better understand this struggle at the local level—namely, how other disenfranchised groups shaped the contours of the movement for their own needs—and, fill in a gap in Civil Rights historiography.1

The analytical disconnect between the works of African-American history and Latino studies can also be seen among scholars that examine minority movements toward full political inclusion across the United States. Some argue that Latinos and other disenfranchised groups were the beneficiaries of the African-American struggle to achieve civil rights and, therefore, their participation in the Civil Rights Movement was peripheral. Others contend that this approach belittles the other movements that arose in later years.2 What results from this is that there is a separation between the study of the larger movement and efforts in the Latino community for social justice. The sum total of the Black, Puerto Rican, and other freedom movements of the period—sometimes in alliance, sometimes not—made a far larger and more varied change in American law than our current understanding of the Civil Rights Movement allows. The initiatives by the Puerto Rican community in the 1970s to enforce legislation concerned with language-access, however, is not peripheral to the study of the “long” Civil Rights Movement but an integral part of it.

An alternate framework, the “long” Civil Rights Movement, views the struggle to secure civil rights before 1954 and after 1968 as equally important as the “classic” phase of the movement.


Civil Rights historians tend to divide the movement into distinct phases. The earliest phase of the movement encompasses events that occurred before 1954. The “classic” phase begins with Brown v Board of Education in 1954 and ends either with the signing of the Voting Rights Act (VRA) in 1965 or the passage of the Civil Rights Act and the assassination of Martin Luther King (1968). The emergence of Black Nationalism (or Black Power) and other events related to the Civil Rights movement in the late 1960s are seen as separate phenomena apart from the “classic” phase of the movement. An alternate framework, the “long” Civil Rights Movement, views the struggle to secure civil rights before 1954 and after 1968 as equally important as the “classic” phase of the movement. While the debate continues over which conceptualization is more accurate, the “long” interpretation provides not only a space to include events that fall outside of the “classic” chronology but also opens up a space to broaden the parameters of the movement for civil rights by including the efforts of other disenfranchised groups in addition to African-Americans.3

The political and social context in which Arroyo v. Tucker occurred, the tactics employed in pursuing class-action litigation, and its outcomes provide a vehicle for understanding how Puerto Ricans in Philadelphia were active contributors to the larger Civil Rights movement. In many ways, Diaz and Teitelbaum echoed the arguments and strategies of other groups like the NAACP Legal Defense Fund and the Mexican American Legal Defense and Education Fund (MALDEF), which also utilized litigation to ensure that disenfranchised groups had equal access to the mechanisms of politics.4 The VRA allowed lawsuits like Arroyo v. Tucker to move forward even though this law contained no provision in 1973 guaranteeing Spanish access to the ballot box. Cases like Arroyo v. Tucker helped to expand not only the electorate, but provided a space for other disenfranchised communities to change the scope of the Civil Rights movement. Arroyo v. Tucker, while not as dramatic as the Mendez v. Westminster (which held that segregation of Mexican-American students to be unconstitutional), Hernandez v. Texas (which established that Mexican-Americans were protected under the 14th Amendment), or Brown v. Board of Education decisions in 1954, was no less important for the Puerto Rican community in Philadelphia (Strum 2010).5 Not only did Arroyo v. Tucker secure Spanish-language ballots for individual Puerto Rican voters, allowing them equal access to the political process, but it also set the stage for the political development of this community in the late 1970s and early ’80s.


Ciudad del Amor Fraternal6

In order to understand how Arroyo v. Tucker was a critical component of the Puerto Rican struggle for civil rights, we must look closely at how the city of Philadelphia and the Civil Rights Movement were changing during the late 1960s and early ‘70s. To call attention to and combat widespread voter disenfranchisement in the American South, African-American civil rights advocates peacefully marched from Selma to Montgomery in March 1965 and were attacked by state troopers. In response, Congress moved the VRA relatively quickly through the legislature, and President Johnson signed the VRA in August 1965.7 This Act strengthened the provisions of the 15th Amendment as well as suspended (and eventually banned) the use of literacy tests to abridge the right to vote throughout the nation. In addition, the VRA specified that jurisdictions with a history of voter discrimination could not implement changes in election law or voting procedures without the approval of the U.S. District Court in Washington, D.C., or the U.S. Attorney General (Laney 2008: summary page). While proponents of the “classic” Civil Rights Movement chronology look at the VRA as the end of the story, this Act actually began a new chapter in the struggle for language equality.

Section 4(e) of the VRA 42 U.S.C. §1973b (e) states that

Congress hereby declares that to secure the rights under the Fourteenth amendment of

persons educated in American-flag schools in which the predominant classroom language

was other than English, it is necessary to prohibit the States from conditioning the right

to vote of such persons on ability to read, write, understand, or interpret any matter in the

English language.8

The existence of this language in the VRA was an explicit recognition of groups like Puerto Ricans who, while predominantly Spanish speaking, were at least nominally a part of the American body politic after 1898. While this clause in the VRA did not explicitly endorse the use of languages other than English in elections, it was a response to an earlier lawsuit raised by Puerto Ricans to vote in Spanish, and it created opportunities for legal challenges to language discrimination at the ballot box with the formation of organizations like the National Association of Puerto Rican Civil Rights in 1965 and PRLDEF in 1972 (Thomas 2010: 217).9

A few days after President Johnson signed the VRA, the Watts section of Los Angeles erupted in five days of racial violence. Detroit and Newark


both faced similar disturbances in 1967, while Philadelphia endured three separate race riots in the years leading up to 1970.10 According to Nixon, Frank Rizzo (mayor of Philadelphia from 1972 to 1980) was an exemplar of the “silent majority,” which emerged in reaction to the gains made by the Civil Rights Movement (Paolantonio 1993: 147). While previous mayors favored a policy of “restrained integrationism,” Rizzo saw during his time as Police Commissioner in the 1960s that American cities were being divided by racial politics; in response, he was determined to use his power to stifle the efforts of the Student Nonviolent Coordinating Committee (SNCC) and other similar groups (Paolantonio 1993: 84–5).11 He would utilize his power as mayor in much the same way. An investigation by the Pennsylvania State Committee of the United States Commission on Civil Rights came to the conclusion that Rizzo’s actions resulted in “the deterioration of police-community relations for minorities and white dissidents” (Paolantonio 1993: 135). Rizzo, however, presided over a diminished city. While Philadelphia’s population in 1960 was slightly over 2 million, the city was beginning to dwindle by 1970 (US Department of Commerce, Bureau of the Census 1971: 8).

Puerto Ricans living in Philadelphia in the 1970s bore witness to these changes in their adopted city while confronting their own unique set of challenges. While a report released by the Philadelphia Commission on Human Relations (PCHR) in 1954 indicated that Philadelphia’s Puerto Rican population was approximately 7,300, this community had increased to over 40,000 by 1970.12 This community was concentrated in particular sections of Philadelphia and generally had higher rates of poverty than both Whites and African-Americans.13 In addition, the PCHR found that this growing community “rarely used civic agencies for help. When they need advice, they consult Spanish-speaking people” (Siegel et al. 1954: vi). Perhaps Puerto Ricans in Philadelphia were hesitant to utilize civil agencies because of their experience with language discrimination in the city. In the years leading up to 1970, Puerto Ricans encountered hostility when interacting with different civic institutions; they were often being greeted with comments like “Why don’t you go back if you don’t speak English” or at other times refused service altogether (Whalen 2001: 213–7).


During the 1960s, Puerto Ricans had made limited in-roads into Philadelphia’s Democratic machine and, in collaboration with the Democratic Party, began to organize get-out-the-vote campaigns in their own neighborhoods to register more voters.

Although Puerto Ricans faced language and residential segregation, the community did organize to participate in Philadelphia civic life as a means to improve their living conditions and make their collective voice heard. During the 1960s, Puerto Ricans had made limited in-roads into Philadelphia’s Democratic machine and, in collaboration with the Democratic Party, began to organize get-out-the-vote campaigns in their own neighborhoods to register more voters. Even representatives of the Island’s government encouraged Puerto Ricans in Philadelphia to register to vote. Joseph Monserat, head of the Migration Division of the Puerto Rican Department of Labor, stated,

If you remember Puerto Rico, you remember the vote is destiny of the people. It doesn’t

matter what party—register and vote. The vote is the defending of happiness for you, so

social justice will come to pass. Each of you look for five more people. Take them and

register and vote. It will be five more nails in the structure of happiness and righteousness.14

This begs the question why members of the growing Puerto Rican community would cultivate ties with the local Democratic Party. The more likely explanation points to the political hegemony the Democratic Party in Philadelphia exerted in city politics since 1952. In addition, local politicians of the Democratic Party in the post-War period attempted to engage this growing community into the fabric of civic society through English-language assimilation initiatives like earlier waves of European immigrants. A more basic and straight-forward motivation for this working relationship could have been more material in nature. During the 1960s, local Puerto Rican organizations like the Council of Spanish-Speaking Organizations (a local community-based group more commonly referred to as Concilio) needed the support of the City Hall in order to gain access to War on Poverty funds that were controlled by Mayor Tate (Morales Carrión 1983: 256; Adams et al. 1991: 125–34; Arnau 2012: 58). Although alliances existed among some segments of the Puerto Rican community with the Democratic Party, these relationships


did not signify full integration of these “new immigrants” into the social and political benefits of citizenship.

These attempts to forge ties with the Democratic Party were tempered by others who were beginning to express skepticism about the prospect of equal citizenship. Carlos Morales, president of the Concilio, said that “Puerto Ricans have been taken advantage of because of the language barrier and their low income level ….” (Whalen 2001: 213–7). Although internal debate took place among the Puerto Ricans about the value of voting in Philadelphia elections, there did not appear to be any discussion as to whether they should have the option of voting in Spanish. While the generation of Puerto Rican community leadership in Philadelphia before 1970 did not utilize the rhetoric or tactics of groups like SNCC or the Black Panthers, the influence of cultural nationalism would soon be felt by a younger generation of Puerto Ricans after 1970—people like Nelson Diaz.

A Brief Cast of CharactersNelson Diaz was born in East Harlem in 1948 and grew up as a rather sickly child in a series of rat-infested tenements where drug abuse and gang violence were commonplace. His health and his academics improved after having the opportunity to move into public housing and participating in organized sports. While Diaz was working on his undergraduate degree at St. John’s University, rioting engulfed Harlem in the wake of the assassination of Martin Luther King. Diaz made the decision to relocate and attend Temple University Law School in 1969. He would get his first taste of civil rights advocacy while at Temple. Diaz and the nine African-American law school students at Temple threatened to leave if the University did not actively recruit more students of color. The protest was publicized in local newspapers, and as a result, Temple began to recruit more Black and Latino law students. After being the first Latino to graduate from Temple’s law school in 1972, Diaz contemplated returning to New York City but was convinced to stay in Philadelphia by one of his professors (Diaz 2013: 1–4; Vazquez 2013).

While working as a Public Defender, Diaz immersed himself in the affairs of the local Puerto Rican community. He provided pro bono work to help revitalize the Latino business district, often working with a local group called the Spanish Merchants Association. Diaz also worked to pressure City Hall and the Philadelphia School District to hire Latino teachers and administrators to work in local schools and represented militant groups like the local chapter


of the Young Lords Party. During his time in Philadelphia, Diaz became increasingly resentful of the racial issues he encountered:

I believe in this whole, ‘justice’ and the American way. I had the colonial mentality…. I

have an awakening of the fact that in this country, people of color are totally discriminated

[against], including me …. So I revolted against the law; I get very radical. After my first

year, I get very radical … I figured the only way that I could do things to anybody was I had

to sue ‘em all. I was suing people for everything. (Diaz 2013: 15).

They wanted to vote but were unable to because neither could read and write in English.

It was through his work in his newly adopted community that Diaz first met Peggy Arroyo and Petra Gonzales. Diaz’s work as Public Defender and his volunteer work earned him a reputation as someone to go to when legal assistance was needed. Diaz could not remember exactly how he met Arroyo and Gonzales; while Diaz conducted meetings with them at Temple Law School’s Legal Aid Program. He stated that he could have met them through any of his other community activities. Diaz did recall that Arroyo and Gonzales were low-income, single mothers who were born and educated in Puerto Rico. They wanted to vote but were unable to because neither could read and write in English. Their lack of English proficiency was problematic since the November 1973 elections contained a complicated loan issue and an amendment to the Pennsylvania Constitution on the ballot that would not be translated into Spanish.15

While a more nuanced discussion of gender in this case is beyond the scope of this article, the dearth of testimony from Arroyo and Gonzales must be highlighted. The various documents and briefs in this litigation provide very little details about either plaintiff. What we do have is Nelson Diaz’s recollection of those initial meetings. He asked Arroyo and Gonzales if they were willing participate in a lawsuit to gain Spanish translations of the ballots and other voting materials. “As I remember them they were no different than maybe my mother … very cooperative, bien sencilla, and didn’t question the basis of what I doing …. They saw me as this young kid who was trying to do the right thing” (Diaz 2013).16 The description of Gonzales and Arroyo as compliant and maternal reflects the class and gendered dimensions of


the interactions between male lawyer and female client. This silencing of Puerto Rican women plaintiffs was unfortunately nothing new in the United States Courts system. In 1904 the US Supreme Court heard arguments in the Gonzalez v. Williams case where the voice of the plaintiff, Isabel Gonzalez, was conspicuously absent (Earman 2008: 15).

Nelson Diaz and Herbert Teitelbaum met through Diaz’s connection with PRLDEF Executive Director Cesar Perales. After securing Arroyo’s and Gonzales’ support to file suit, Diaz sought to bring some of PRLDEF’s resources to bear in Philadelphia. Cesar Perales, one of the founders of PRLDEF, suggested that Diaz communicate with their new employee Herbert Teitelbaum, a young lawyer born and raised in New York. He completed his undergraduate studies at Brandeis University and completed law school at New York University. Teitelbaum began working as an Associate Attorney with Widett and Kruger P.C. in 1968. He moved on to Skadden, Arps, Slate, Meagher & Flom, P.C. in 1970. In 1972, Teitelbaum was hired by PRLDEF as Legal Director (Teitelbaum n.d.). He gained valuable experience on the issue of bilingual voting though his work on the Torres v. Sachs lawsuit in New York, an action that would aid in setting the legal precedent for Arroyo v. Tucker (Torres v. Sachs 1974).

The game’s afoot … Nelson Diaz and Herbert Teitelbaum began to correspond in January 1973. Diaz initially contacted Teitelbaum about his clients Peggy Arroyo and Petra Gonzalez to see if Teitelbaum was interested in bringing the resources and experience of PRLDEF to bear against the City of Philadelphia and the Commonwealth of Pennsylvania. Teitelbaum, at first, was hesitant—“Before we move on any of the bilingual election cases outside of New York we are waiting for a decision from the Federal Court here. Our theory is that a strong precedent in New York will be helpful in other jurisdictions.” In addition Teitelbaum advised Diaz to take a look at a similar case in Chicago, PROPA v. Kusper (1973), that PRLDEF was also assisting with.17 By October 1973, the courts in New York handed PRLDEF a favorable decision in Torres v. Sachs, and Diaz and Teitelbaum began taking steps to begin their work in Philadelphia. After contacting both Secretary of State (Dolores Tucker) and the local Elections Commission, Diaz came to the conclusion that neither was particularly interested in voluntarily providing Spanish translations in local elections. Thinking about these events forty years later, Diaz mused, “Tucker


just, you know, bucked it to the local Commission in Philadelphia and the interesting thing about the local Commission in Philadelphia, the guy who was the Chairman of the local Commission, didn’t give a damn about it” (Diaz 2013: 10). While Tucker (at the state level) was responsible for setting the terms of elections, the various City Commissioners of Elections at the municipal level were responsible for implementing elections; therefore, both levels of government were culpable.

While city and state officials procrastinated, Diaz and Teitelbaum were prepared to move forward and file an injunction to halt the upcoming November election. Although the injunction was never meant to indefinitely postpone the November election, it served as a necessary legal gambit to force action. In his October 5th affidavit, Herbert Teitelbaum stated that the - “… central issue raised in this lawsuit is whether an election conducted by defendants exclusively in the English language violates the Voting Rights Act of 1965.”18 He cited three recent cases to support his claim: (1) Torres v. Sachs in New York (1973), where the court ordered bilingual election materials including the use of translators; (2) the Puerto Rican Organization for Political Action (PROPA) v. Kusper (1973) in Chicago, in which the court issues a preliminary injunction forbidding the exclusive use of English in elections; and (3) Lopez v. Dinkins (1973) when bilingual school board elections were ordered throughout New York City’s thirty-two school districts. Teitelbaum added that since no affirmative response was received during earlier inquiries, he and Diaz were forced to conclude that the defendants had no plans to provide bilingual materials or translators for the November 6th election.19

In a press release prepared October 5th, Diaz and Teitelbaum informed the public that a lawsuit had been filed in Federal Court charging that the Secretary of State and the Philadelphia County Commission of Elections denied qualified Puerto Rican voters their right to full and equal access to the November 6th ballot. The complaint alleged that an all-English ballot would violate the voting rights of those Puerto Rican citizens of Pennsylvania who have difficulty understanding English. While the discrimination in this case might not have been as blatant as in Smith v. Allwright (1944), where the Court ruled that not allowing African-Americans to participate in Democratic primaries was a violation of the 15th Amendment, the two young attorneys in Arroyo v. Tucker charged that the lack of bilingual assistance of Puerto Rican voters in Pennsylvania was in violation of both the 1965 Voting Rights Act and the Constitution (see Arroyo v. Tucker 1974 and Dittmer 1995: 2). The upcoming


November election was particularly important because it contained a proposed state-constitutional amendment in addition to the names of the candidates.20 Cesar Perales stated: “We are optimistic that Pennsylvania’s November 6th election will be bilingual. Puerto Ricans in New York, New Jersey, Illinois and now Pennsylvania are demanding that their rights be fulfilled under the Constitution of the United States and the Voting Rights Act. The lawsuit is only the beginning of the Fund’s involvement in Pennsylvania.”21

Arroyo v. Tucker was, therefore, not only a lawsuit confined only to Philadelphia but part of a larger push by Puerto Ricans to assert their civil rights; PRLDEF (like the NAACP Legal Defense Fund and MALDEF) became the vehicle for this push.

PRLDEF was already engaging in voting rights cases outside the confines of the Puerto Rican community in New York City. The Philadelphia Bulletin reported on October 6, 1973, that a United States District Court in Newark, New Jersey, asked that New Jersey election officials provide Spanish translations on ballots. This request came as a result of a lawsuit filed by PRLDEF. When asked about the lawsuit in New Jersey and the recent successful lawsuit in New York, Perales stated:

We are gratified and encouraged by the great support and excitement which our victory in

New York has created with the Puerto Rican community. Our people have been citizens of

this country for decades, yet it is only now that we are gaining the power to cast an informed

and effective vote. We are hoping that bilingual elections will become a reality in Puerto

Rican communities throughout the country.22

Arroyo v. Tucker was, therefore, not only a lawsuit confined only to Philadelphia but part of a larger push by Puerto Ricans to assert their civil rights; PRLDEF (like the NAACP Legal Defense Fund and MALDEF) became the vehicle for this push.

The courts system moved incredibly fast to this lawsuit. “You get an injunction right away when you request an injunction because they [the defendants] have so many days to respond to the injunction” (Diaz 2013: 10). Judge Lord issued an order on the evening of Friday, October 5th restraining Pennsylvania Secretary of State Delores Tucker and other officials from


publishing or advertising any material concerning the November 6th election until after a hearing. Lord’s October 12th preliminary order directed the city’s Commission of Elections to place unofficial Spanish translations of the November 6th ballot, including all propositions and amendments, at polling places within Philadelphia. Furthermore, wherever the 1970 census tracks contained 5 percent or more persons who were Spanish-language dominant voters, then bilingual (Spanish and English) representatives must be provided at polling places to help Spanish-dominant Puerto Rican voters.23 In his column in the Philadelphia Bulletin, Diaz characterized this decision as a giant step forward in gaining respect and recognition for Philadelphia’s Puerto Rican community.24 “Voting has seemed irrelevant to Puerto Ricans here, but this step will increase the participation of Puerto Rican voters in this city and throughout the country.”25 This preliminary order like the previous injunction, while only a temporary solution, put pressure on the defendants while the two sides negotiated a more permanent resolution.

During the first meeting of the respective attorneys, Mr. Marvin Halpern (a candidate for judge) was brought in by the city commissioners for his knowledge of Puerto Rican affairs to testify about his knowledge of the Puerto Rican community. He claimed to understand the Puerto Rican community and stated that 90 percent of Philadelphia’s Puerto Ricans could speak, understand and read English. Diaz disagreed with this, citing a study conducted by the Commonwealth Office of Puerto Rico demonstrating that 98 percent of Puerto Ricans living in the continental United States claim Spanish as their primary language. Eugene Maier asked, “If we do this for you, will we have to do the same for those who speak other languages?” Diaz pointed out that Puerto Ricans are not foreigners, having been granted citizenship in 1917 by the Jones Act. “The government has never required them [Puerto Ricans] to speak English, and Spanish remains their mother tongue”.26

According to Diaz, as a result of bilingual voting materials not being available to Puerto Rican voters, the ability of all Puerto Ricans to participate in elections held in Philadelphia would be seriously and substantially impaired. It was clear that Puerto Ricans would be forced to either vote for or against amendments that were unintelligible or refrain from voting altogether. “Under either circumstance, [the] plaintiffs’ fundamental right to vote will be impaired.”27 Diaz added that not having bilingual election materials for Puerto Rican voters rendered their votes meaningless and was “tantamount to absolutely denying [the] plaintiffs their right to vote.”28


If Diaz and Teitelbaum were to be successful in this lawsuit, they would have to demonstrate that Puerto Ricans in Philadelphia represented a class whose rights were being infringed upon by monolingual elections. “The class consists of all persons eligible to vote in general elections over which [the] defendants have jurisdiction either jointly or severally who are of Puerto Rican birth or descent residing in Pennsylvania who speak, read, write and understand English with severe difficulty or not at all.”29 Diaz argued that Arroyo and Gonzales had claims typical of other Puerto Ricans living in Philadelphia and that a class action lawsuit was the only practical method for the fair and efficient adjudication of this complaint, for the substance of the complaint not only pertained to the individual plaintiffs but to the class as a whole.30

While Diaz argued that this lawsuit was an effort on behalf of the local Puerto Rican community, this litigation was not prompted through grassroots organization and community representatives who shared the educational and economic status of their fellows. Diaz, it could be argued, by virtue of his education and status was slightly removed from the daily struggles of working-class and poor Puerto Ricans in Philadelphia. Although Diaz had worked tirelessly on behalf of a number of individuals and organizations within Philadelphia’s Puerto Rican community, he admitted that he was looking for a way out of the Public Defender’s Office by 1973 due to conflicts with his supervisor over his work in local Puerto Rican protests (Diaz 2013: 7–8). He wanted to utilize this lawsuit to increase the number of Puerto Rican voters, get Puerto Rican candidates elected, and establish a PRLDEF office in Philadelphia. Arroyo v. Tucker, therefore, provided an opportunity to satisfy both his personal objectives as well as provide another path for community political development. Diaz would not be alone in this regard.

When the NAACP Legal Defense Fund legal team began its work on Brown v. Board of Education (1954), the attorneys sought out black parents in Topeka, Kansas, who would be willing to serve as plaintiffs. Objections to the Brown lawsuit were raised by Black teachers who risked losing their jobs if schools were integrated. A more recent case, Fisher v. University of Texas (2008), which challenged affirmative action policy in higher education admissions, was funded by Edward Blum’s organization Project on Fair Representation. “In the Fisher case, while the young woman may have lent her name to the lawsuit, the case before the Court has very little to do with her. Her name appears just five times in the thousands of words that make up the body of the complaint” (Hannah-Jones 2013). While the motivation behind the filing of the Arroyo


lawsuit might be viewed as somewhat self-serving, success in this litigation would not only affect Diaz’s agenda but the larger fight to guarantee fair access to all language-minorities to the ballot box.

Diaz sought to demonstrate that a substantial number of potential voters could be negatively impacted by the lack of bilingual voting materials. He argued that, according to the 1970 Census, “In the Philadelphia area, alone, there are in excess of 30,000 Puerto Ricans.”31 The Census Bureau stated approximately 26,948 Puerto Ricans lived in Philadelphia while local Philadelphia newspapers estimated that the number of Puerto Ricans in Philadelphia in 1973 was approximately 90,000 people. Some of the older, more conservative leaders of Philadelphia’s Puerto Rican community disagreed with the U.S. Census count and that this undercount was purposeful to reduce the community’s political power.32 While the waves of earlier immigrants who came to the United States for the most part remained here, Puerto Ricans migration has been characterized by cyclical migration back and forth between the island and the mainland, the typical undercounting of poor neighborhoods, and the difficulty counting a group, which had no category of its own may account for the discrepancy over the actual population in Philadelphia (García Passalacqua 1994: 104).

While the debate over the actual numbers of Puerto Ricans in the city continued, some questioned whether the essential claims of the lawsuit were applicable to Philadelphia. Joe Davidson, a reporter with the Philadelphia Bulletin, felt that the VRA did not apply to Puerto Ricans in Philadelphia since the trigger mechanism in the act only applied when less than 50 percent of the voting age population of a state or county failed to register or vote in recent presidential elections. Philadelphia, after all, was not the American South, where Jim Crow stifled generations of African-Americans from exercising the franchise (Kousser 1974: 224). While the 50 percent threshold was not an issue for the overall voting population in Philadelphia, Lord’s preliminary order held to the standard created in Torres v. Sachs, which established the precedent that if 5 percent of a given district’s population was Puerto Rican, then that district was obligated to provide Spanish translations to all voting materials.33

Teitelbaum began to contact other attorneys between November 1973 and January 1974 to probe their interest in bringing their resources to bear on this case and possibly expand its scope across Pennsylvania. He reached out to his colleagues at the United States Department of Justice Civil Rights Division, the Attorney General of Pennsylvania, and the Pennsylvania Legal


Services Center (PLSC). David H. Wilderman, a lawyer with the PLSC, shared the news of the preliminary order with his colleagues and began to marshal his resources for a possible statewide push for bilingual elections. In order to assess whether the results of this case might be extended to other regions of the state, Teitelbaum and Diaz would have to demonstrate that sufficient numbers of Spanish-dominant Puerto Ricans lived in census tracts outside of Philadelphia. To accomplish this, they enlisted the help of Melvin Shuster, the Deputy Attorney General of Pennsylvania, who was able to provide the information they needed.34 According to the data, a successful outcome in Arroyo v. Tucker could impact eight additional counties across the state.

By February 1974, Teitelbaum was pressing for a summary judgment, arguing that “There are no genuine issues of material in dispute…. The only issue remaining is one of law: the legality of conducting elections in English only.”35 The parties met again to discuss the feasibility of adding Spanish text to the existing voting machines.36 The defendants argued that Spanish signs posted on the walls of election sites were one issue but including Spanish translations on voting booths was something else entirely. To present his case that bilingual voting machines were feasible Diaz enlisted the aid of Lloyd A. Wallace, Director of the Model Cities Community Organization Department for the City of Philadelphia. Wallace went on record to state that not only was it possible to have bilingual voting machines, but that it had already been done for Model Cities elections one month earlier, where the machines were in both English and Spanish.37

As negotiations continued, both sides offered slightly different proposals that would eventually become parts of the final version of Judge Lord’s order. The defendants, for example, suggested in one draft of the order that bilingual elections be required only in certain sections of the city; and that they provide at least one individual who was fluent in both languages at the various polling places Spanish-dominant Puerto Ricans were likely to frequent; and that the city was to publicize elections “in a way that reflects the language characteristics of the plaintiffs.”38 Diaz and Teitelbaum’s draft preferred the term “sufficient numbers” rather than “at least one” with regard to the number of translators available and felt the term “in all media proportionately in a way that reflects the language characteristics of the plaintiffs” would better protect Spanish-dominant voters in Philadelphia.39 Both sides agreed that voter registration forms and sample paper ballots be translated and that conspicuous bilingual signs at polling places and registration sites be posted.


County Census Tract Total Population

Puerto Rican Population

Percentage Spanish Language Population

Percentage

Berks 9 2591 145 5.6 145 5.612 3347 374 11.2 458 13.713 2910 184 6.3 299 10.322 2462 218 8.9 252 10.223 2609 221 8.5 251 9.624 1925 242 12.6 262 13.6

Bucks 1006 4806 301 6.3 304 6.31007 4113 225 5.5 303 7.41022 551 47 8.5 55 10

Chester 3024 3399 203 6 217 6.43026 4360 228 5.2 250 5.7

Delaware 4037 99 76 13 17.1 27 35.5Lancaster 8 3415 369 10.8 451 13.2

9 3386 504 14.9 525 15.514 5104 437 8.6 452 8.915 1396 164 11.7 200 14.316 3203 360 11.2 460 14.4

Lehigh 5 2883 166 5.8 235 8.212 2087 137 6.6 153 7.3

Montgomery 2009 02 1635 89 5.4 96 5.92074 1528 83 5.4 112 7.3

Northampton 105 5378 593 11 786 14.6109 3711 200 5.4 531 14.3112 5336 741 13.9 1028 19.3113 3125 948 30.3 1132 36.2

Philadelphia 2 1179 88 7.5 88 7.543 99 91 27 29.7 27 29.7125 3243 165 5.1 204 6.3126 811 155 19.1 155 19.1129 829 113 13.6 113 13.6130 1055 116 11 140 13.3133 4581 952 20.8 1063 23.2134 7436 1820 24.5 2058 27.7141 4731 314 6.6 375 7.9142 3319 552 16.6 580 17.5144 4744 788 16.6 990 20.9145 4785 879 18.4 924 19.3155 6608 779 11.8 840 12.7156 5295 1538 29 1675 31.6157 3656 360 9.8 463 12.7162 5351 2088 39 2237 41.8163 6271 1257 20 1307 20.8164 9554 2578 27 2973 31.1175 11370 3204 28.2 3724 32.8176 13344 1586 11.9 1872 14193 128 53 41.4 53 41.4198 7103 914 12.9 1060 14.9199 6308 583 9.2 711 11.3

Table 1: Percentage of Puerto Rican Population by Census Tract - 1974


Lord stated in an interview: “This is a novel matter in this (Eastern Pennsylvania) jurisdiction but not elsewhere.”

According to Diaz, Judge Lord demonstrated a keen understanding of the problems Puerto Rican voters faced and was highly instrumental in negotiating the settlement. Lord identified the central issue in this case—namely—whether or not Philadelphia’s English-only election system infringed upon the plaintiff ’s voting rights: “We agree the right to vote means more than the mechanics of marking a ballot or pulling a lever.” He concluded that, under Section 1 (the equal protection clause) of the 14th amendment and the VRA, conducting elections in English for American citizens who do not speak English would be a violation of their rights. Lord stated in an interview: “This is a novel matter in this (Eastern Pennsylvania) jurisdiction but not elsewhere.”40 Diaz was unaware that Lord already had a history of ruling on cases involving civil rights issues in Philadelphia. In 1966, Lord ruled that the Pennsylvania Public Accommodation Act required Girard College to admit African-Americans. While this ruling was reversed by the U.S. Third Circuit Court of Appeals in February 1967, this did not stop Lord from continuing to press Girard College to open its doors to racial minorities. In July 1967, Lord ruled that Girard College’s exclusion of African-Americans was a violation of the 14th amendment (which applied to the private school because of its tax-exempt status) (Collier-Thomas and Franklin 1994: 49).41

In his March 1974 opinion, Judge Lord based his judgment on the existing case law. It was clear to Lord that section 4(e) of the VRA 1965 forbade any State from “conditioning the right to vote” of a person educated in an American-flag school where English was not the language of instruction on his or her degree of fluency in the English language. This clause, therefore, explicitly protected the Puerto Rican community residing in the United States and on the island. Since the passing of the Jones Act in 1917, residents of Puerto Rico were citizens of the United States. Thus, unlike naturalized citizens, Puerto Ricans did not need to demonstrate fluency in English. Indeed, since 1947 the United States had encouraged Puerto Rico to teach its school children in Spanish, reversing an earlier decision mandating that all schools on the island teach only in English. While Puerto Ricans in the United States remained subject to other modes of sanctioned discrimination such


as police brutality and residential segregation (much the same way African-Americans were during their Great Migration), there was a slow shift in policy to recognize the importance of language for this group and incorporate them (under conditions that remain grossly unequal) into the body politic (Arroyo v. Tucker 1974; Morales Carrión 1983: 271–2).

For Lord, the critical issue in this case was whether Philadelphia’s English-only election system constituted a limitation on the plaintiffs’ franchise as prescribed in Section 4(e). Although Lord felt this issue was new for Pennsylvania, he agreed with Diaz and Teitelbaum that identical issues were presented to a district court in New York in Torres v. Sachs and to the Seventh Circuit Court of Appeals of Illinois in PROPA v. Kusper. In Torres, the court determined that “the conduct of an election in English only violates plaintiffs’ rights under the Voting Rights Amendments of 1970 which enforce the Fourteenth Amendment to the Constitution of the United States and the Civil Rights Act of 1871.” In PROPA, the court held that the Voting Rights Act mandated that “a Spanish-speaking Puerto Rican is entitled to assistance in the language he can read or understand” and that the “right to vote” included the right to an “effective vote”; it was not merely the right to gain physical access to a voting booth (Arroyo v. Tucker 1974).

Lord agreed that the franchise meant more than the mechanics of marking a ballot or pulling a lever. He determined that the plaintiffs could not cast an “informed” or “effective” vote without demonstrating an ability to comprehend the registration and election forms and the ballot itself.

Lord also referred to other cases that did not specifically pertain to Puerto Ricans when he made his decision. In Garza v. Smith (Texas 1970), the court held that the right to vote included the “right to be informed” and found a Texas statute violated the equal protection clause by permitting assistance to blind voters but not to illiterate voters. A narrow construction of the “right to vote” was similarly rejected in United States v. Louisiana (1966), United States v. Mississippi (1966), and United States v. Post (1969). Lord agreed that the franchise meant more than the mechanics of marking a ballot or pulling a lever. He determined that the plaintiffs could not cast an “informed” or “effective” vote without demonstrating an ability to comprehend the registration and election forms and the ballot itself. The English-only election materials therefore


constituted a device conditioning the rights of plaintiffs. In essence, the sole use of English language materials at the voting booth became akin to literacy tests utilized against African-Americans during Jim Crow. Such an election process, according to Lord, could not withstand scrutiny under the Voting Rights Act (Arroyo v. Tucker 1974).

In the aftermath of Lord’s decision, Teitelbaum busied himself with contacting his colleagues at the NAACP Legal Defense Fund and MALDEF to keep them abreast of the final order issued by Lord.42 Meanwhile, Diaz worked on assisting the County Commissioners with the Spanish translation for the May and November elections in 1974.43 Diaz had the opportunity to observe different polling places and voter registration sites across the Puerto Rican sections of Philadelphia after Lord issued the preliminary injunction and noted that while bilingual materials and machines were in place at most sites, others did not have interpreters.44 Not satisfied with the manner in which the City of Philadelphia and the Commonwealth of Pennsylvania were implementing Lord’s order, Diaz and Teitelbaum filed a motion for Contempt and Sanction on February 21, 1975.45 They charged that the voter registration site in City Hall had no bilingual employees and that the defendants had no intention of hiring more than three bilingual staffers for the forty voter registration sites in Philadelphia’s Spanish-speaking communities. They added that while advertisement of elections occurred in Philadelphia’s English-language media, no effort was made to distribute similar advertisements in the city’s Spanish-language media and that the Federal District Courts have the authority to punish the refusal of any party to comply with the Court’s orders.46

A week later, the defendants’ responded to this motion stating that as of March 12, 1975, they intended to employ sufficient numbers of Spanishspeaking personnel to fully service the Spanish-speaking sections of the city. While it is not clear what the defendants meant by “sufficient numbers” they stated that the “Commissioners’ long experience and expertise will determine the number of persons required for full compliance with the Court’s Order.” While the defendants agreed to print bilingual notices and instructions for election sites, they disagreed with Diaz and Teitelbaum that they were obligated to post election notices via Spanish local media and added that the Elections Commissioners did not have the funds to do so.47 Deputy City Commissioner Harvey Rice stated that his office was working to register the Spanish-speaking community. Rice argued that, “The effort is there … as far as I recall, we’ve covered those [Puerto Rican] areas as much as we’ve


covered others…,” even though his office was working with limited personnel and a reduced budget.48 During the decade of the 1970s, cutbacks in federal aid forced the Philadelphia officials to rely on local tax revenue in order to govern (Adams et al. 1991: 131). These cutbacks would negatively impact the manner in which the Elections Commissioners went about enacting Lord’s order. James Thomas Tucker argues, however, that language assistance provisions of the VRA can be implemented in a cost-effective manner through partnerships with local language minority groups (Tucker 2009: 161). In this instance Lord, however, made no distinction in this instance between the intent to hire more bilingual staff and the actual hiring of bilingual staff.

Assessing the ImpactWhile Spanish-dominant Puerto Ricans were now legally guaranteed access to bilingual ballots, it did not necessarily translate immediately into more electoral participation and representation. Diaz hoped that the success of Arroyo v. Tucker would encourage more Puerto Ricans to vote and move into electoral politics in Philadelphia in the same way that African-Americans were doing in the 1970s (Diaz 2013: 25). The actual number of Puerto Rican voters in Philadelphia, however, is difficult to determine. The Philadelphia Bulletin, for example, stated that 15,000 Puerto Ricans were registered voters. Another article in the Philadelphia Inquirer speculated that there were fewer than 9,500 Puerto Ricans registered to vote. Journalist Juan Gonzalez argued that the number of registered Puerto Ricans increased from 5,000 to 10,000 by 1979. Diaz’s view was more pessimistic; he guessed that less than 4,000 voted with any regularity (Diaz 2013: 20; Arnau 2012: 66; Gonzalez 1987–88: 38).49 The apparent weakness of the Puerto Rican electorate in Philadelphia is confusing when one considers the dramatic increase in population during the decade. Eugene Ericksen and other scholars studying this community argued that the Puerto Rican population increased during the 1970s by as much as 76 percent.50 Although the result of Arroyo v. Tucker created opportunities for Spanish-dominant Puerto Ricans in Philadelphia to vote, other factors continued to hamstring their electoral power until the late 1970s.

The failure to increase the number of Puerto Rican elected officials in Philadelphia in the wake of Arroyo v. Tucker can be partially explained by the lack of an independent electoral infrastructure within this community during the 1960s and ‘70s. Matthew Countryman notes that during the 1970s, “Black Power activists in Philadelphia and elsewhere developed electoral strategies


that sought not only to elect blacks to represent majority black communities, but then to hold those elected officials accountable to the movement’s agenda of fundamental socioeconomic and institutional reform” (Countryman 2006: 326). Before the lawsuit, the Puerto Rican community in Philadelphia had one elected official at the state level from 1968 to 1970, and much of the established Puerto Rican leadership supported Frank Rizzo.51 While some Puerto Ricans worked closely with the city’s Democratic Party, this collaboration did not translate into voting power or support for Puerto Rican candidates during the period (Arnau 2012: 66).

What was it about living in Philadelphia that prevented Puerto Ricans from selecting their own political representation even though they now had access to Spanish-language ballots?

A study of Puerto Rican voting turnout revealed that between 1972 and 2000, the island of Puerto Rico had significantly higher rates of voter participation than Pennsylvania or any other state in the country (Cámara Fuertes 2004: 13). What was it about living in Philadelphia that prevented Puerto Ricans from selecting their own political representation even though they now had access to Spanish-language ballots? Political scientists looking at Latino electoral participation attribute a variety of factors that curtail the ability of Latino communities to select their own political representation. These include the relative youth of the population, lack of education, higher rates of poverty, and lack of participation in community organizations. In addition, factors that exist outside of the Latino community also affect its political participation and electoral power such as gerrymandering, voter intimidation, and outright violence (Hero 1992; DeSipio 2004; Garcia and Sanchez 2008). A study of Puerto Rican political representation found that at the municipal level, this community’s electoral power was divided among three different Philadelphia City Council districts. Thus, the mix of at-large and district seats and the drawing of City Council district borders negatively influenced the ability of Puerto Ricans to flex their electoral muscles (Ericksen at al. 1985: 109–10).52

The electoral breakthroughs Diaz hoped for would not occur until the 1980s and were the result of increased electoral access and participation, as well the creation of political organizations independent of the local Democratic Party. The creation of this independent organizational machine


was the result of Mayor Rizzo’s attempt to change the city charter so that he could run for a third term in office in 1978. A coalition of young, leftist Puerto Ricans formed a group called Puerto Ricans United Against Rizzo and collaborated with African-Americans and White liberals to defeat the charter change (Adams et al. 1991: 134; Gonzalez 1987–88: 237). The campaign doubled the number of registered Puerto Rican voters in the city and led to the creation of The Puerto Rican Alliance (La Alianza) which, while continuing to organize protests, ran Puerto Rican candidates in state legislature elections for the first time since 1968. Although La Alianza began to dissolve in 1982, the experience gained by running independent political campaigns and guaranteed access to bilingual election materials contributed to the electoral victories of Ralph Acosta in 1984 and Angel Ortiz in 1985—this despite the obstacles presented by Philadelphia’s political structure (Gonzalez 1987–88; Whalen 2001: 237; Vázquez-Hernández 2005: 102).

Arroyo v. Tucker was important to the long Civil Rights movement in other ways beyond its impact in Philadelphia. When the VRA was being reviewed and reconsidered in 1975 (when its provisions were set to expire), the utilization of bilingual election materials in jurisdictions not covered by the special provisions of the VRA was looked at very closely by the United States Commission on Civil Rights. The lawsuit in Philadelphia was referred to specifically, in conjunction with a few others, to establish a precedent for expanding and legitimizing bilingual access to the election process for the entire country (US Commission on Civil Rights 1975: 24). Even though certain jurisdictions were beginning to voluntarily implement bilingual elections procedures, Spanish speakers reported that many obstacles to voter registration and participation continued to persist in much the same way that African-Americans had their voting ability challenged during the Reconstruction.53 After the debates surrounding the extension of the VRA concluded, the VRA was rewritten to include protecting language minorities, such as Spanish-speakers, Asian-Americans, American Indians, and Alaskan Natives, and was signed by President Gerald Ford on August 6, 1975 (Laney 2008).

Arroyo v. Tucker did have other inadvertent effects. This lawsuit transpired during what I would argue was the language-rights phase of the “long” Civil Rights movement (1968-1975). The gains made in bilingual voting and bilingual education during this period prompted strong reactions against bilingualism in different parts of the country, which coalesced into the English-Only movement. Various measures limiting the 1975 language provision of the


VRA were proposed, such as Proposition O in San Francisco in 1983 and Proposition 38 in a 1984 state-wide referendum in California. Neither of these measures was successful in circumventing the 1975 VRA language provision, but they are indicative of a growing organized resistance to bilingual elections. Advocacy groups supporting English-Only policies founded in the wake of the language-rights phase, such as US English (1983) and English First (1986), have continued to press for the repeal of bilingual protection provisions at the federal level (Crawford 1992: 192; Schmidt 2000: 21; Woolard 1990: 126). Advocates of English-Only policies have argued that bilingualism in the electoral process is not only expensive, but threatens our sense of national unity (Schmidt 2000: 167; Tucker 2009: 224). What these advocates fail to remember is that groups brought through conquest into the American political orbit, such as Puerto Ricans, Mexicans, and Native Americans, have all been granted paths to citizenship without an English-language prerequisite. While a more thorough exploration of the relationship between the “long” Civil Rights Movement and the rise of the English-Only movement is beyond the scope of this study, it does pose tantalizing questions for future research.

ConclusionAs the demographics of the United States continue to change, the issue of bilingual voting will become only more important. Although Arroyo v. Tucker and the subsequent modification to the VRA in 1975 legitimized bilingual voting, attempts to limit the electoral power of Spanish-speaking citizens have continued. In 1993, for example, there were reports that campaign workers were walking door-to-door prior to Election Day in Latino neighborhoods in Philadelphia encouraging voters to cast absentee ballots. These workers allegedly misled voters about the documents they were signing, and steered voters into voting for particular candidates. Voters also reported that they were misled about the state’s absentee voting laws and were told by these campaign workers that they could vote from home (People for the American Way and NAACP n.d.: 10).

Measures to restrict the ability of American citizens to exercise their right to vote and limit the language used to conduct public affairs were taken up not only by campaign workers but also on the floor of the Pennsylvania Capitol building. In 2011, Pennsylvania state legislators proposed that a bill that would mandate that all state, municipal, and school district business be conducted only in English. Representative RoseMarie Swanger sponsored the bill and


stated, “I think we’ve been catering to outsiders very much” (Warner 2011). In 2012, the Pennsylvania state legislature approved a bill to enact a strict voter ID law one month before the November general election, but the state’s Supreme Court temporarily blocked the measure (Bronner 2012). Jaime Estades has argued that limiting the electoral ability of the poor, African-Americans, and language minorities is as American as apple pie, but a thorough examination of the strategies and arguments in Arroyo v. Tucker demonstrates how Puerto Ricans, like other racialized groups in American history, have successfully advocated for their civil liberties (Guzman 2012).

As Puerto Ricans and other Latino groups grow demographically, historians will need to pay greater attention to how these communities organized internally, interacted with the mechanisms of political power at the local level, and expressed their own unique concerns.

While critics of the long framework have argued that its contours are too pliable, this flexibility is one of its strengths. If we can extend the periodization of Civil Rights Movement, then we can also broaden it to include Asians, indigenous peoples, and Latinos. As Puerto Ricans and other Latino groups grow demographically, historians will need to pay greater attention to how these communities organized internally, interacted with the mechanisms of political power at the local level, and expressed their own unique concerns. The case of Arroyo v. Tucker is particularly instructive since it demonstrates how disenfranchised language minorities, much like the African-American community years earlier, utilized existing legislation to press the justice system for equal protection under the law.54 It is conceivable that some scholars may object to a “broad” movement that too closely links the struggles of African-Americans with other issues such as language-rights or marriage-rights. That concern, however, would be predicated on the belief that individual identity is singular and bears no hint of intersectionality and that the various currents within a “broad” construction of the Civil Rights Movement are not in dialogue with one another. Scholars like Hugh Davis Graham have begun the process of reconceptualizing the relationship between the various strands of this “broad” movement by bringing together both race and gender in his analysis, but more work needs to be done on this front (Graham 1990). Indeed, a wider conceptualization of the struggle for equality in American history could serve


not only as a corrective to previously forgotten struggles but also elevate other disenfranchised groups to the center of the historical narrative.


ACKNOWLEDGEMENTS:

The author would like to thank Thomas Kessner, Kathleen McCarthy, Clarence Taylor, Juan Cartagena,

Víctor Vázquez, Cambridge Ridley Lynch, the fellow students in his cohort, the members of the 20th

Century Historian’s Working Group, and the participants of the Puerto Ricans in the United States

symposium at Rutgers University for their feedback and comments.

NOTES

1 Harvard Sitkoff (2008: 258) makes the case that in order to better understand the impact of the

struggle for legal equality, one must examine how the movement functioned at the local level. While

much of Carmen Whalen’s (2001) work looks at Puerto Ricans in Philadelphia, she does not situate her

analysis within the literature on the Civil Rights Movement. Matthew Countryman (2006) does look at this

movement in Philadelphia and connects Black Power ideology with the “long” Civil Rights Movement and

yet Puerto Ricans merit no mention as participants in this endeavor. For a more comparative approach,

which examines African-Americans and Chicanos in the American Southwest, see Behnken (2011). The

strongest argument thus far for including Puerto Ricans and other disenfranchised groups into the civil

rights narrative comes from Thomas (2010), Lilia Fernandez (2012), and Johanna Fernandez (2009, 2011).2 Skrentny (2002) states that the federal government, “had shown a special interest in blacks, Latinos were

like blacks, and therefore politicians and civil-rights administrators pursuing constituents or justice goals

targeted this group with special policy initiatives.” In her article Dowd-Hall writes, “The view of the 1970s

as a tragic denouement belittles … other movements that emerged from the black freedom struggles and

institutionalized themselves” (2005: 1254).3 For arguments in favor of the “long” civil rights movement see Theoharis and Woodard (2003) and Self

(2005). For arguments against the “long” Civil Rights Movement framework see Cha-Jua and Lang (2007)

and Arnesen (2009). 4 Other lawsuits involving discriminatory voting practices during the 1970s include cases litigated by the

Mexican American Legal Defense and Education Fund (MALDEF) such as White, et al. v. Regester, et al.

(1973). Another lawsuit was filed by the NAACP Legal Defense Fund was United Jewish Organizations of

Williamsburgh v. Carey (1977).5 Mendez v. Westminster was a precursor to Brown v. Board of Education and the first federal case to find

that de jure segregation (in that case of Mexican children in California) creates a sense of inferiority and

isolation that could not be countenanced under the 14th Amendment even under the separate but equal

doctrine (Soltero 2006: 37–47). For more on the Brown v. Board of Education decision, see Kluger (1976),

Patterson (2001), and Klarman (2004). 6 “City of Brotherly Love” in Spanish, author’s translation.7 For more on the Selma to Montgomery march see Branch (2006: 44–154) and for more on the passage

of the VRA, see Branch (2006: 275–7). For a much shorter version see US Department of Justice (2009).8 Memorandum of Law in Support of Plaintiffs’ Motion for Preliminary Injunction [Series 1B Box 13


Folder 9] Nelson Diaz Papers (Collection 3079), Historical Society of Pennsylvania, 5.9 For more on PRLDEF, see Latino Justice (n.d). For more on Section 4(e) of the VRA, see Laney (2008:

12) and Culliton-Gonzalez (2008). For earlier challenges to English-only voting see Cartagena’s (2005: 205)

discussion of the 1959 case Camacho v. Rogers. 10 For more on Watts, see Branch (2006: 293–323). For more on Detroit and the factors that led up to

riot in 1967, see Sugrue (1996). For more on the Newark riots see Mumford (2008). For more on the

1964 and 1967 race riots in Philadelphia, see Countryman (2006). For more on the 1953 Puerto Rican race

riot in Philadelphia see Whalen (2001: 183).11 For more on Rizzo and his response to civil rights protests see Countryman (2006: 225–6). For more

on “restrained integrationism” see Sugrue (2008: 121).12 For more on the PCHR report on Puerto Ricans in 1954 see Whalen (2001: 183–88). For more on the

dispute over the 1970 census count of Puerto Ricans in Philadelphia see Class Action Complaint [Series

1B, Box 13, Folder 9], Nelson Diaz Papers (Collection 3079), Historical Society of Pennsylvania, 4, and

Philadelphia Evening Bulletin, Newspaper clipping collection, “Phila. Puerto Rican Leaders Clash with Census

Bureau,” August 10, 1975 (Philadelphia, TUUA).13 “Low-income” was classified as a family of four earning $3,748 or less annually. These

“neighborhoods” consisted of contiguous census tracts with a combined population of 20,000 or more.

One of the interesting features of 1970 census is that “Hispanic,” “Latino,” or “Puerto Rican” were not

available as categories for self-identification. “Hispanic” was used for the first time on the 1980 Census.

While the 1970 Census considered Puerto Ricans as “white” for purposes of racial categorization, the

supplementary report does highlight “Persons of Spanish Language,” which can be used to track Puerto

Ricans in Philadelphia. This report indicates that that “Persons of Spanish Language” were concentrated

in four different sections of the city: neighborhoods 1 and 3 (the area of North Philadelphia from

west from Broad Street east to B Street and north from Lehigh Avenue south to Oxford Avenue),

neighborhood 2 (Northern Liberties and Poplar), and neighborhood 5 (Spring Garden) (US Department

of Commerce, Bureau of the Census 1974: 1–18). 14 Philadelphia Evening Bulletin, Newspaper clipping collection, Spanish Frank Keeps Tabs on 15th Ward Puerto

Ricans, September 4, 1961 (Philadelphia, TUUA) and Look for Five New Voters Each Puerto Rican is Told,

August 4, 1960 (Philadelphia, TUUA), and Philadelphia Evening Bulletin, Newspaper clipping collection,

Patrons Seek Improved Conditions for Puerto Ricans, June 11, 1964 (Philadelphia, TUUA).15 Affidavits of Peggy Arroyo and Petra Gonzalez [Series 1B Box 13 Folder 9], Nelson Diaz Papers

(Collection 3079), Historical Society of Pennsylvania. 16 Bien sencilla in this context refers to someone who is humble and not garish in their appearance or

mannerism.17 Herbert Teitelbaum, “Memo to Nelson Diaz,” January 2, 1973. Records of the Puerto Rican Legal

Defense and Education Fund, Archive of the Puerto Rican Diaspora. Litigation Files, Box 1 Folder 2.

Centro de Estudios Puertorriqueños, Hunter College, City University of New York.


18 Affidavit of Herbert Teitelbaum [Series 1B, Box 13 Folder 9], Nelson Diaz Papers (Collection 3079),

Historical Society of Pennsylvania. 19 Affidavit of Herbert Teitelbaum [Series 1B, Box 13 Folder 9], Nelson Diaz Papers (Collection 3079),

Historical Society of Pennsylvania. 20 Press Release dated October 5, 1973 [Series 1D Box 32 Folder 12], Nelson Diaz Papers (Collection

3079), Historical Society of Pennsylvania. The two constitutional amendments up for a vote in November

1973 were state-level amendments. Question 1 pertained to the Vietnam Conflict Veteran’s Compensation

Act, and Question 2 on the ballot pertained to initiating criminal proceedings without the need for a

grand jury indictment. Both measures were passed. See Pennsylvania Legislature (2007). 21 Press Release dated October 5, 1973 [Series 1D Box 32 Folder 12], Nelson Diaz Papers (Collection

3079), Historical Society of Pennsylvania.22 Philadelphia Evening Bulletin, Newspaper clipping collection, “Court Asked to Set Spanish Ballots in NJ,”

Philadelphia Evening Bulletin, October 6, 1973 (Philadelphia, TUUA).23 Undated Press release from Temple University School of Law [Series 1D Box 32 Folder 12], Nelson

Diaz Papers (Collection 3079), Historical Society of Pennsylvania. “Order of the United States District

Court for the Eastern District of Pennsylvania” [Series 1b Box 13 Folder 9], Nelson Diaz Papers

(Collection 3079), Historical Society of Pennsylvania. Nelson Diaz, “Memo to Herbert Teitelbaum,”

March 27, 1974. Records of the Puerto Rican Legal Defense and Education Fund, Archive of the Puerto

Rican Diaspora. Litigation Files, Box 1 Folder 2. Centro de Estudios Puertorriqueños, Hunter College,

City University of New York.24 Philadelphia Evening Bulletin, Newspaper clipping collection, Nelson Diaz, “Ahora, Ahora” Philadelphia

Bulletin, October 28, 1973 (Philadelphia, TUUA).25 Charles F. Thomson, “Phila. To Provide Nov 6 Ballots in Spanish,” The Philadelphia Bulletin, October

14, 1973. Records of the Puerto Rican Legal Defense and Education Fund, Archive of the Puerto Rican

Diaspora. Litigation Files, Box 1 Folder 2. Centro de Estudios Puertorriqueños, Hunter College, City

University of New York. 26 Philadelphia Evening Bulletin, Newspaper clipping collection, Nelson Diaz, “Ahora, Ahora” Philadelphia

Bulletin, October 28, 1973 (Philadelphia, TUUA).27 Class Action Complaint [Series 1B, Box 13, Folder 9], Nelson Diaz Papers (collection 3079), Historical

Society of Pennsylvania, 4.28 Class Action Complaint [Series 1B, Box 13, Folder 9], Nelson Diaz Papers (collection 3079), Historical



Society of Pennsylvania, 4. 31 Class Action Complaint [Series 1B, Box 13, Folder 9], Nelson Diaz Papers (collection 3079), Historical


Society of Pennsylvania, 4.32 Charles F. Thomson, “Phila. To Provide Nov 6 Ballots in Spanish,” The Philadelphia Bulletin, October

14, 1973. Records of the Puerto Rican Legal Defense and Education Fund, Archive of the Puerto

Rican Diaspora. Litigation Files, Box 1 Folder 2. Centro de Estudios Puertorriqueños, Hunter College,

City University of New York. Philadelphia Evening Bulletin, Newspaper clipping collection, Joe Davidson,

“Phila. Puerto Rican Leaders Clash with Census Bureau” Philadelphia Evening Bulletin, August 10, 1975

(Philadelphia, TUUA).33 Philadelphia Evening Bulletin, Newspaper clipping collection, Joe Davidson, “Phila. Puerto Rican Leaders

Clash with Census Bureau,” Philadelphia Evening Bulletin, August 10, 1975 (Philadelphia, TUUA), “Order”

[Series 1B Box 13 Folder 9], Nelson Diaz Papers (Collection 3079), Historical Society of Pennsylvania,

and Arnau, “Evolution of Leadership,” 77.34 Letter from Deputy Attorney General of Pennsylvania Melvin Shuster to Herbert Teitelbaum, January

8, 1974. The data on Table 1 came directly from Shuster’s office. “Regarding the computer print-out, the

program was designed to pick out those census tracts in which the concentration is 5% or greater. As you

will note, the figures for Spanish-speaking persons are usually slightly higher than the figures for Puerto

Ricans, and occasionally are identical. This suggests that notwithstanding the different classifications

defined in census manuals, the Spanish-speaking category includes the Puerto Rican figure, and that much

of the difference probably represents Puerto Rican persons as well.” Records of the Puerto Rican Legal


Centro de Estudios Puertorriqueños, Hunter College, City University of New York.35 “Affidavit in Support of Plaintiffs’ Motion for Summary Judgment”. Records of the Puerto Rican

Legal Defense and Education Fund, Archive of the Puerto Rican Diaspora. Litigation Files, Box 1 Folder

1. Centro de Estudios Puertorriqueños, Hunter College, City University of New York.36 “Affidavit of Nelson Diaz,” February 8, 1974. Records of the Puerto Rican Legal Defense and

Education Fund, Archive of the Puerto Rican Diaspora. Litigation Files, Box 1 Folder 1. Centro de

Estudios Puertorriqueños, Hunter College, City University of New York.37 “Affidavit of Lloyd A. Wallace,” February 8, 1974. Records of the Puerto Rican Legal Defense and

Education Fund, Archive of the Puerto Rican Diaspora. Litigation Files, Box 1 Folder 1. Centro de

Estudios Puertorriqueños, Hunter College, City University of New York. “Bilingual Election Suit Time

Spent Memo,” March 27, 1974. Records of the Puerto Rican Legal Defense and Education Fund, Archive

of the Puerto Rican Diaspora. Litigation Files, Box 1 Folder 2. Centro de Estudios Puertorriqueños,

Hunter College, City University of New York.38 “Counter Proposed Order,” Records of the Puerto Rican Legal Defense and Education Fund, Archive

of the Puerto Rican Diaspora. Litigation Files, Box 1 Folder 1. Centro de Estudios Puertorriqueños,

Hunter College, City University of New York.39 Records of the Puerto Rican Legal Defense and Education Fund, Archive of the Puerto Rican



University of New York.40 Philadelphia Evening Bulletin, Newspaper clipping collection, “Bilingual Vote Setup Ordered,” Philadelphia

Evening Bulletin, March 27, 1974 (Philadelphia, TUUA) and Philadelphia Evening Bulletin, Newspaper clipping

collection, Nelson Diaz, “Ahora, Ahora” Philadelphia Bulletin, October 28, 1973 (Philadelphia, TUUA).41 This book mentions Judge Lord and the Girard College protests but makes no mention of the Arroyo

v. Tucker lawsuit. Girard College is a private school located in Philadelphia that was founded by Stephan

Girard in 1833 to educate poor, white, male orphans. The school is now integrated and admits girls. 42 Records of the Puerto Rican Legal Defense and Education Fund, Archive of the Puerto Rican


University of New York. 43 Elections in Pennsylvania are held in both May and November. 44 Letter from Nelson Diaz to Herbert Teitelbaum, January 11, 1974. Records of the Puerto Rican Legal


Centro de Estudios Puertorriqueños, Hunter College, City University of New York.45 “Notice of Motion,” February 21, 1975. Records of the Puerto Rican Legal Defense and Education

Fund, Archive of the Puerto Rican Diaspora. Litigation Files, Box 1 Folder 1. Centro de Estudios

Puertorriqueños, Hunter College, City University of New York.46 “Motion for Contempt and Sanctions” and “Memorandum of Law in Support of Motion,” Records of

the Puerto Rican Legal Defense and Education Fund, Archive of the Puerto Rican Diaspora. Litigation

Files, Box 1 Folder 1. Centro de Estudios Puertorriqueños, Hunter College, City University of New York.47 Defendants’ Answer to Plaintiffs’ Motion for Contempt and Sanctions, February 28, 1975. Records of

the Puerto Rican Legal Defense and Education Fund, Archive of the Puerto Rican Diaspora. Litigation

Files, Box 1 Folder 2. Centro de Estudios Puertorriqueños, Hunter College, City University of New York.48 Philadelphia Evening Bulletin, Newspaper clipping collection, “Phila. Puerto Rican Leaders Clash With

Census Bureau”, Philadelphia Evening Bulletin, August 10, 1975 (Philadelphia, TUUA).49 See also Charles F. Thomson, “Phila. To Provide Nov 6 Ballots in Spanish,” The Philadelphia Bulletin,

October 14, 1973. Records of the Puerto Rican Legal Defense and Education Fund, Archive of the

Puerto Rican Diaspora. Litigation Files, Box 1 Folder 2. Centro de Estudios Puertorriqueños, Hunter

College, City University of New York. Philadelphia Evening Bulletin, Newspaper clipping collection, Joe

Davidson, “Phila. Puerto Rican Leaders Clash with Census Bureau,” Philadelphia Evening Bulletin, August

10, 1975 (Philadelphia, TUUA). The exact number of Puerto Rican voters is difficult to determine

because, prior to 1980, the Philadelphia County Board of Elections tracked electoral participation by race

(defined as either African-American or White) alone. 50 The Puerto Rican population in Philadelphia increased 26,702 in 1970 up to 46,990 in 1980 (Ericksen,

et al. 1985: 1). 51 German Quiles served as State Representative for the 180th District from 1968 to 1970 (Philadelphia

Evening Bulletin, Newspaper clipping collection, “Puerto Ricans Begin Drive for ‘Brown People’ Label,”


December 27, 1970 (Philadelphia, TUUA)). For more Puerto Rican support for Rizzo see Whalen (2001:

235). 52 Images 1 and 2 to compare the concentration of the Puerto Rican population and the City Council

District borders in 1980. Images from the Free Library of Philadelphia.53 In an examination of the VRA’s effects and reactionary voter suppression among Latinos in Texas

during the 1970s, a case was cited where an election judge told a “bilingual clerk who was trying to assist

a voter that if Chicanos cannot speak English, they should not be permitted to vote” (People for the

American Way and NAACP n.d.: 21).54 It is important to remember that the law utilized in this case, Section 4(e) of the VRA, was specifically

created to protect Puerto Ricans in New York City from electoral discrimination. See Cartagena (2005:

204–6).

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Put a Sticker on It: Civil Rights, Bilingual Voting, and Puerto Ricans in Philadelphia in the 1970s

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