The U.S. Supreme Court case Gutierrez del Arroyo v. Graham in 1912 revolved around the issue of whether or not a Puerto Rican court had jurisdiction over an American citizen, Mr. Graham, who was serving as a public official in Puerto Rico at the time of his alleged offense. The plaintiff, Gutierrez del Arroyo, claimed that Graham had violated his civil rights by unlawfully imprisoning him and sought damages for this violation under federal law (the Civil Rights Act). However, the defendant argued that since he was acting within his capacity as a public official when he ordered the arrest and detention of Gutierrez del Arroyo on suspicion of fraud against government funds - which is considered to be part of maintaining peace and order - he should be immune from such lawsuits. The Supreme Court ruled in favor of Graham stating that while it's true that individuals have certain protections against unlawful imprisonment under federal law; these protections do not extend to actions taken by officials performing their duties unless they clearly exceed their authority or act with malicious intent – neither condition being met here according to available evidence.

The dissenting opinion in the case of Gutierrez del Arroyo v. Graham argued that the plaintiff, a Puerto Rican citizen, should be considered a U.S. citizen and thus entitled to constitutional protections under the Fifth Amendment. The justice disagreed with the majority's interpretation of Downes v. Bidwell (1901), arguing it did not establish that territories were foreign countries for constitutional purposes but rather left open questions about their status. He contended that Congress had intended to grant citizenship through its actions following Spain’s cession of Puerto Rico after Spanish-American War, including imposing taxes and duties as if it was part of U.S., establishing courts there based on American law system, and passing Foraker Act which provided civil government for island residents similar to stateside citizens’. Therefore, he believed these actions indicated an intent by Congress to incorporate Puerto Rico into United States thereby making its inhabitants US citizens deserving full protection under Constitution.