GATEWAY TO WHITENESS:
USING THE CENSUS TO
REDEFINE AND RECONFIGURE
HISPANIC/LATINO IDENTITY, IN
EFFORTS TO PRESERVE A WHITE
AMERICAN NATIONAL IDENTITY
GUSTAVO CHACON MENDOZA ∗
I. INTRODUCTION
Recent census projections approximate that by 2050 Whites will
make up less than 50% of the United States national population. 1
Latinos are one of the fastest growing groups in the nation. 2 From July
1, 2004 to July 1, 2005, the Hispanic community “accounted for . . .
49% . . . of the national population growth of 2.8 million.” 3
The increasing minority population is threatening the traditional
White American identity. This threat exists only through the inclusive
and exclusive manner in which race and ethnicity are currently defined.
As the American identity evolves, the decreasing White majority must
find new ways to preserve the White national identity. The United
States has a long history of reclassifying and redefining race, ethnicity
and different sub-groups in America, in the census and elsewhere. 4
∗
J.D. Graduate, University of La Verne College of Law, 2008, B.A. University of
California Santa Barbara, 2003.
1. Angela D. Johnson, In 2050 Half of U.S. Will Be People of Color, DIVERSITY INC.,
Oct. 11, 2006, http://www.diversityinc.com/public/311.cfm.
2. See id.
3. Press Release, U.S. Census Bureau, Nation’s Population One-Third Minority (May
10, 2006) (on file with the University of La Verne Law Review), http://www.census.gov/
Press-Release/www/releases/archives/population/006808.html [hereinafter One-Third
Minority].
4. See BETSY GUZMÁN, U.S. CENSUS BUREAU, THE HISPANIC POPULATION, CENSUS
2000 BRIEF 1 (2001), http://www.census.gov/prod/2001pubs/c2kbr01-3.pdf (last visited
Nov. 15, 2007).
160
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With the increase of the minority population, the redefining of race and
ethnicity emerges as the eventual method of preserving the White
American identity. The census will be the tool used to narrow the
understanding of ethnicity and broaden the definition of “Whiteness,” in
efforts to maintain the current American identity.
This Comment argues that the Hispanic/Latino/Spanish population
and its multiple sub-groups are the most susceptible to being
reclassified and defined as White. Latin America has a history of
encouraging the ‘whitening’ of its national populations, which was
pressed upon these societies by strong influential European racial
theories between the 1880’s and 1930’s. 5 In the United States, the
census has been used as a device to include and exclude groups within
the national identity. Mexicans and Puerto Ricans are the largest
Hispanic sub-groups within the U.S. 6 Sub-groups with smaller
populations in the U.S. may lack the political power to avoid being
organized under the Black/White binary and excluded from any separate
ethnic categories. Forcing Hispanic groups into the Black/White binary
will obscure the rapid increase of the “minority” population and
simultaneously increase the White majority numbers.
Part I examines the increasing Latino population and statistical
analysis of the census regarding present numbers and future population
projections. Also discussed are the methods the census uses to collect
the data, and what racial and ethnic categories are used.
Part II discusses the White American national identity and
addresses the following questions: What has created the White
American Identity? How has the census been used to perpetuate the
continued existence of the current national identity? How will the
census be used to maintain and preserve the White national identity?
Lastly, does history predict that there will be a continuation of the
White American identity?
Part III analyzes why the Hispanic grouping is most susceptible to
being incorporated solely within the Black/White Binary. First, the
influence of Latin American ideology pressed upon many Hispanic
group members has created a preference for White identification.
Second, the census’s ability to include Hispanic sub-groups into the
5. Tanya Katerí Hernández, Multiracial Matrix: The Role of Race Ideology in the
Enforcement of Antidiscrimination Laws, A United States-Latin America Comparison, 87
CORNELL L. REV. 1093, 1108 (2002).
6. ROBERTO P. RAMIREZ, U.S. CENSUS BUREAU, WE THE PEOPLE: HISPANICS IN THE
UNITED STATES, CENSUS 2000 SPECIAL REPORTS 2 (2004), http://www.census.gov/prod/2004
pubs/censr-18.pdf.
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national identity pushes these groupings to prefer a more specific
classification of their own identities. Lastly, a large number of Hispanic
group members currently classify themselves within the racial
categories as White.
Part IV discusses why Hispanic groups will not benefit from being
considered simply “White.” The United States has a long history of
discriminating against and negatively stereotyping Hispanic group
members. Surnames, language, accents or even physical features will
continue to distinguish the Hispanic groups from the White community.
If categorized as White, discrimination against members of these groups
will only be harder to trace and protection will be more difficult to
obtain. White privilege will continue to exist, but Hispanics will not
benefit from it the same way many poor White groups have done in the
past. Since a larger percentage of Hispanics than other Whites are poor,
the incorporation will create a permanent poor White sub-class by
erasing their ethnicity and incorporating them only within the White
racial category.
II. THE STATISTICAL THREAT: THE INCREASING MINORITY POPULATION
A. The Increasing Hispanic Population
In the past few decades the Hispanic population has dramatically
increased. According to a U.S census Bureau study, the total Hispanic
population residing in the United States in 1990 was 22.4 million. 7 In
2000 the census found that there were 35.3 million Hispanics in the
U.S., which was 12.5% of the national population. 8 Thus, between
1990 and 2000 there was a 57.9% increase in the total Hispanic
population. 9 In 1990, 70 of the top 100 largest cities in the United
States had a non-Hispanic White majority; by 2000, just 52 of the 100
largest cities had a non-Hispanic White majority. 10
7. Id.
8. Id. at 1.
9. Id.
10. John A. Powell, A Minority-Majority Nation: Racing the Population in the TwentyFirst Century, 29 FORDHAM URB. L.J. 1395, 1397–1402 (2002). The statistic also includes
other factors, such as whites leaving the city and moving to suburban areas. Eric Schmitt,
The Census: The Nation; Whites in Minority in Largest Cities, the Census Shows, N.Y.
TIMES, Apr. 30, 2001, http://query.nytimes.com/gst/fullpage.html?res=9E02E2DC1F39F933
A057 57C0A9679C8B63.
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More recent studies confirm these results. Between 2000 and 2004,
the Hispanic population increased by 17%. 11 In 2000, non-Hispanic
Whites made up approximately 70% of the total U.S. population. 12 By
2004, this had dropped to approximately 67%. 13 The most recent study
reveals that from July 1, 2004 to July 1, 2005, the U.S. Hispanic
population grew by 3.3%. 14 The increase in that one year represented
49% of the total U.S. population growth, 1.3 million of the 2.8 million
in total. 15 By 2005, one out of every seven Americans was Hispanic,
and that number continues to grow due to immigration and high birth
rates. 16
Hispanic families and households are also increasing at a high
17
Compared to non-Hispanic Whites, Hispanics are more than
rate.
twice as likely to have three or more children under the age of
eighteen. 18 Hispanic women in every age group have more children
then White women, and also expect to have more children. 19 While
9.3% of non-Hispanic Black and White women expect not to give birth
during their life time, just 5.7% of Hispanic women feel the same
way. 20 In 2000, the median age for the national population was 35.3
years, but the median age for Hispanics was 25.9 years old. 21
Overall it is predicted that the United States population will
increase from 282.1 million in 2000 to 419.9 million by 2050. 22 By that
11. U.S. CENSUS BUREAU, RACE AND HISPANIC ORIGINS IN 2005 2, at tbl. 1 (2006),
http://www.census.gov/population/pop-profile/dynamic/RACEHO.pdF [hereinafter
HISPANIC ORIGIN].
12. ELIZABETH M. GRIECO & RACHEL C. CASSIDY, U.S. CENSUS, OVERVIEW OF RACE
AND HISPANIC ORIGIN, CENSUS 2000 BRIEF, C2KBR/01-1, 10 (2001), http://www.census.gov
/prod/2001pubs/cenbr01-1.pdf.
13. HISPANIC ORIGIN, supra note 11, at 2 tbl. 1.
14. One-Third Minority, supra note 3.
15. Id.
16. Daniel J. Grimm, The Demographics of Genetic Surveillance: Familial DNA
Testing and the Hispanic Community, 107 COLUM. L. REV. 1164, 1178 (2007).
17. See HISPANIC ORIGIN, supra note 11, at 3.
18. Grimm, supra note 16, at 1179. See U.S. CENSUS BUREAU, STATISTICAL
ABSTRACT: 2006 EDITION 55, (2006), http://www.census.gov/compendia/statab/2006/popula
tion/pop.pdf. The report explains the methods of calculating ethnic and racial enumerations
within the census. Id. It reports that 3,559,000 White married couples out of 44,197,000
and 480,000 out of 4,146,000 African American married couple families had three or more
children under the age of eighteen. Id. at 55 tbl. 62. In 2004, 1,220,000 Hispanic married
couples out of 6,227,000, had three or more children under the age of eighteen. Id.
19. Grimm, supra note 16, at 1179–80 (citing Teresa A. Sullivan, A Demographic
Portrait, in HISPANICS IN THE UNITED STATES: AN AGENDA FOR THE TWENTY-FIRST CENTURY
13 (Pastora San Juan Cafferty & David W. Engstrom eds., 2000)).
20. Id. at 1180.
21. GUZMÁN, supra note 4, at 7.
22. Johnson, supra note 1.
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time, the historical White groups will no longer constitute a majority of
this nation’s population. 23 The estimates are that African-Americans
will account for 15% of the population, Asian-Americans for 8% and
Latinos for 24%. 24
B. The Sub-Groups Within the Hispanic Population
Among the Latino population, the 2000 census found that those of
Mexican descent were by far the largest sub-group, accounting for 20.9
million. 25 This is 59% of the total U.S. Latino population. 26 Those of
Puerto Rican descent were the second largest group, a dramatically
smaller number of 3.4 million. 27 Other Latinos together accounted for
5.5 million. 28 The Commonwealth of Puerto Rico has an additional 3.8
million Hispanics, who are excluded from the U.S. census count. 29 The
U.S. census totals include only the 50 U.S. States and exclude the
Puerto Rican Commonwealth and the U.S. Island areas. 30 Although
Puerto Ricans are eligible to join the U.S. military, 31 they are not
counted by the U.S. census. 32
C. The Current State of Race and Ethnicity on the Census, and Its
Evolution
In the 2000 census there was one question (question 5) regarding
ethnicity and a separate question (question 6) regarding race. 33
Between question 4 and question 5, the form instructs the reader to
“please answer both Question 5 and 6.” 34 Question 5, the “ethnicity”
23. Id.
24. Id.
25. Ramirez, supra note 6, at 1. Estimations are based upon population samples and
may vary due to other factors from the sample valuation. Id. The statistics are at a 90%
confidence rate. Id. at 18.
26. Id. at 3.
27. Id. at 1.
28. Id. at 3. The Latino population was comprised of 5.1% Central Americans. Of the
Central American grouping, 22% were Guatemalans, 13% Hondurans, and 39%
Salvadorians. The Latino population was comprised of 4% South Americans, which
included Columbian (35%), Ecuadorian (19%) and Peruvian (17%). Id. at 3.
29. GUZMÁN, supra note 4, at 1.
30. Id.
31. Albert M. Camarillo, Expert Report of Albert M. Camarillo, 5 MICH. J. RACE & L.
339, 351 (1999).
32. GUZMÁN, supra note 4, at 1.
33. U.S. DEPARTMENT OF COMMERCE, BUREAU OF THE CENSUS, UNITED STATES CENSUS
2000 FORM D-2 3 (2000), http://www.census.gov/dmd/www/pdf/d02p.pdf [hereinafter
CENSUS 2000].
34. Id.
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question, asks, “Is this person Spanish / Hispanic / Latino?” 35 The
options are (1) “No, Not Spanish / Hispanic / Latino” (2) “Yes,
Mexican, Mexican Am., Chicano” (3) “Yes, Puerto Rican” (4) “Yes,
Cuban” (5) “Yes, other Spanish / Hispanic / Latino,” with boxes under
to fill in. 36 Question 6, the “race” question asks “What is the person’s
race?” 37 The respondent can choose from “White,” “Black (includes
African Am[erican], or Negro),” “American Indian or Alaska Native,” a
list of Asian races such as Chinese, Filipino, Korean Vietnamese, and
“Some Other Race” with a box to fill in. 38
The Latino/ Hispanic classification in the census has evolved over
time. In the 1930 U.S. census, “Mexican” was a distinct racial (not
35. Id.
36. Id.
37. Id.
38. Id.; see also HISPANIC ORIGIN, supra note 11, at 2.
American Indian and Alaska Native. A person having origins in any of the original
peoples of North and South America (including Central America), and who maintains tribal
affiliation or community attachment.
Asian. A person having origins in any of the original peoples of the Far East,
Southeast Asia, or the Indian subcontinent. It includes people who indicated their race or
races as ‘Asian Indian,’ ‘Chinese,’ ‘Filipino,’ ‘Korean,” ‘Japanese,’ ‘Vietnamese,’ or ‘Other
Asian,’ or wrote in entries such as Burmese, Hmong, Pakistani, or Thai.
Black or African American. A person having origins in any of the Black racial groups
of Africa. It includes people who indicated their race or races as ‘Black, African Am., or
Negro,’ or wrote in entries such as African American, Afro American, Nigerian, or Haitian.
Hispanic or Latino. A person of Cuban, Mexican, Puerto Rican, South or Central
American or other Spanish culture or origin, regardless of race. The term “Spanish origin,”
can be used in addition to “Hispanic or Latino.”
Native Hawaiian and Other Pacific Islander. A person having origins in any of the
original peoples of Hawaii, Guam, Samoa, or other Pacific Islands. It includes people who
indicated their race or races as ‘Native Hawaiian,’ ‘Guamanian or Chamorro,’ ‘Samoan,’ or
‘Other Pacific Islander,’ or wrote in entries such as Tahitian, Mariana Islander, or Chuukese.
White. A person having origins in any of the original peoples of Europe, the Middle
East, or North Africa. It includes people who indicated their race or races as ‘White’ or
wrote in entries such as Irish, German, Italian, Lebanese, Near Easterner, Arab, or Polish.
Some other race. was included in Census 2000 for respondents who were unable to
identify with the five Office of Management and Budget race categories. Respondents who
provided write-in entries such as Moroccan, South African, Belizean, or a Hispanic origin
(for example, Mexican, Puerto Rican, or Cuban) are included in the Some other race
category.
Revisions to the Standards for the Classification of Federal Data on Race and
Ethnicity, 62 Fed. Reg. 58782-01, 58789 (October 30, 1997) [hereinafter Standards for
Classification], available at http://www.whitehouse.gov/omb /fedreg/ombdir15.html..
The OMB defines Hispanic or Latino as ‘a person of Cuban, Mexican, Puerto
Rican, South or Central American, or other Spanish culture or origin regardless
of race.’ In data collection and presentation, federal agencies are required to use
a minimum of two ethnicities: ‘Hispanic or Latino’ and ‘Not Hispanic or Latino.
GREICO & CASSIDY, supra note 12 at 2.
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ethnic or nationality) category. 39 The 1940 census removed the
Mexican race category and created a different identifier, Spanish as the
“mother tongue” category. 40 In the 1950s and 1960s, censuses Latinos
were identified indirectly, such as by categorizing “persons of Spanish
surname.” 41 In 1970, the U.S. census used the term Hispanic for the
first time, which recognized and identified a specific group of people
and created the first ethnicity question on the census questionnaire. 42
However, the version of the 1970 questionnaire that included the
ethnicity question was distributed to only “a 5[%] sample of
households.” 43
The census in 1980 and 1990 asked for
“‘Spanish/Hispanic origin or descent’ and if so, to choose Mexican,
Puerto Rican, Cuban, or other Spanish/Hispanic.” 44 From the 1990
census to the 2000 census not much changed on the ethnicity question,
but the term “Latino” was introduced for 2000. 45
The biggest question is how Hispanics identify themselves on the
census regarding race. According to the 2000 U.S census, 48% of
Hispanics identified themselves as “White” alone. 46 Less than 4% of
Hispanics identified themselves as Black (includes African American,
Negro). 47 Another 42% of Hispanics marked the “Some Other Race”
category. 48 The census found that 6% of Hispanics reported two or
more races, and of that number, 81% marked as one of their choices,
“Some Other Race.” 49 In fact, of the 15.8 million people who marked
the “Some Other Race” category, 97% of them were Hispanic. 50
Hence, “Some Other Race” is also functioning as a de facto Hispanic
category.
III. THE WHITE AMERICAN NATIONAL IDENTITY
A. The Perception of Race and Its Effect on the National Identity
Historically, one can distinguish two different definitions of race:
“(1) race as biological characteristics, historical commonality, or
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
GUZMÁN, supra note 4, at 2.
Id. at 1–2.
Id. at 1.
Id.
Id.
Id.
GUZMÁN, supra note 4, at 1.
GREICO & CASSIDY, supra note 12, at 10.
Id.
Id.
Id.
Id. at 11.
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essential identity, and (2) race as the erroneous categorization of people,
or the false attribution of traits to people.” 51 Modern science has begun
to recognize that racial classifications are largely arbitrary,52 and that
there is little biological component to race. 53 More often individuals
within the same racial category display greater biological differences
than individuals of dissimilar races. 54 There is also evidence suggesting
that racial differences are based upon events which are historical,
traditional and cultural. 55 Due to social and scientific circumstances, it
is argued that race was socially constructed to subordinate select
groups. 56 The census follows the modern theory of race and finds that
race “generally reflect[s] a social definition of race recognized in this
country.” 57 Additionally, “[t]hey do not conform to any biological,
anthropological or genetic criteria.” 58
The different concepts and perceptions of race, which have
permeated throughout history, have created confusion, which allows the
dominant culture to develop racist stereotypes. 59 Through the dominant
culture’s attempt to define, categorize and subordinate smaller minority
groups, it has simultaneously impacted and defined its own group. 60
Therefore, the creation of the White American national identity is
51. Jayne Chong-Soon Lee, Navigating the Topology of Race, 46 STAN. L. REV. 747,
751 (1994).
52. Saint Francis Coll. v. Al-Khazraji, 481 U.S. 604, 610 n.4 (1987). Distinct racial
categories do not exist and general racial characteristics have been found to have trivial
biological significance. Id. at 610. Due to the fact that people of similar races have greater
biological differences than those of dissimilar races leads most in the scientific field to
believe race is based on sociopolitical reasoning. Id. The biological reasoning behind racial
classifications is highly criticized by both biologists and anthropologists. Id.
53. See Powell, supra note 10, at 1400.
54. Saint Francis Coll., 481 U.S. at 610 n. 4.
55. Naomi Zack, American Mixed Race: The U.S. 2000 Census and Related Issues, 17
HARV. BLACK LETTER L.J. 33, 38 (2001).
56. See Powell, supra note 10, at 1400–01.
57. Press Release, U.S. Census Bureau, Questions and Answers for Census 2000 Data
on Race (Jan. 25, 2002) (on file with the University of La Verne Law Review),
http://www.census.gov/Press-Release/www/2001/raceqandas.html [hereinafter Questions
and Answers].
58. Id.
59. Gloria Sandrino-Glasser, Los Confundidos: De-Conflating Latino/as’ Race and
Ethnicity, 19 CHICANO-LATINO L. REV. 69, 92 n. 91 (1998) (explaining that perceptions of
culture and race are perpetuated by stereotypes which are created though historical events,
political movements, and socio-economic circumstances).
60. George A. Martinez, The Legal Construction of Race: Mexican-Americans and
Whiteness, 2 HARV. LATINO L. REV. 321, 330, 342–44 (explaining why Mexicans were
defined as White while simultaneously stripping them of any White privilege); see also Ian
F. Haney Lopez, Race, Ethnicity, Erasure: The Salience of Race to LatCrit Theory, 85 CAL.
L. REV. 1143, 1159–72 (1997).
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implicated in the subordination of non-dominant groups and also rooted
in events within U.S. history.
There are many illustrations of U.S. history that demonstrate the
rooted ideologies of race and conceptions of White superiority.
Manifest Destiny, rooted in Puritan ideas 61 and rationales of
hemispheric conquest, “effectively declared the superiority of the white
Anglo-Americans.” 62 Early Texas history promoted ideals of filling the
state with a North American (White) population, which would
seemingly harmonize the country and state with a common origin,
language, interest and political view. 63
Ideological perceptions
combined with a lengthy history of slavery and discrimination display
the U.S. preference for a White national identity and also the
establishment of it.
B. The Census’s Contribution To The National Identity
An average is no longer a simple number; it is often a standard. 64
The census “takes individuals and turns them into ‘statistical people,’”65
then creates an “avalanche of numbers” to regulate the person’s
attention in life 66 and individual goals in this new found group standard.
Congress went beyond constitutional requirements in its enumeration of
the population by including explicit racial categories. 67 Because “racial
and ethnic categories are often the effects of political interpretation and
struggle,” 68 the uses of such divisions and classifications in the census
have far-reaching social and political effects. This was evident between
61. Sandrino-Glasser, supra note 59, at 109–10, nn. 155–56; see RODOLFO ACUNA,
OCCUPIED AMERICA: A HISTORY OF CHICANOS 13 (Harpercollins College Div. ed., 3d ed.
1988).
62. Id. Manifest Destiny influenced Anglo-American belief in the establishment of the
City of God on earth. In this belief the chosen people were due salvation because God
graced Anglo-Americans as the custodians of democracy. Id. The destiny was to own and
occupy all land. The creation of stereotypes and discrimination followed in line with the
idea of taking over occupied lands. See id.
63. Id. at 98–99; see ARNOLDO DE LEON, THEY CALLED THEM GREASERS: ANGLO
ATTITUDES TOWARD MEXICANS IN TEXAS 1821–1900 3 (University of Texas Press 1983).
64. Naomi Mezey, Erasure and Recognition: The Census, Race and the National
Imagination, 97 NW. U. L. REV. 1701, 1716 (2003); see Paul Starr, The Sociology of
Official Statistics, in THE POLITICS OF NUMBERS 54 (William Alonso & Paul Starr eds.
1987).
65. Id. at 1719 (citing Lisa Heinzerling, The Rights of Statistical People, 24 HARV.
ENVTL. L. REV. 189 (2000)).
66. Id. at 1715 (citing IAN HACKING, THE TAMING OF CHANCE 1, 1–10 (Cambridge
Univ. Press 1990)).
67. See U.S. Statutes At Large, 1 Cong. Ch. 2; 1 Stat. 101 (1790).
68. Michael Omi, Racial Identity and the State: The Dilemmas of Classification, 15
LAW & INEQ. 7, 10 (1997).
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the 1840s through the 1870s, when six and a half million European
immigrants and just 60,000 Chinese immigrants arrived in the United
States. 69 This created not an immigration problem, but a Chinese
problem, which was laced with confusion on how to classify or color
this new group. 70 When hatred became a national issue, Chinese people
became a recognized category in the 1860 federal census. 71
The census is therefore a tool in constructing identifiable
groupings, which establishes “national identity, group identity and
individual identity.” 72 The use of race in the census gives rise to a
“function of official race classifications . . . [creating] a sense of group
membership or even community where there had been none before.” 73
The census not only acknowledges existing identities, but also takes
particular characteristics to solidify an identity, officially recognizing
those in power and those in the minority. 74
“[T]he idea of ‘nation’ was made possible in the eighteenth
century by the demise of religious and dynastic empires and the rise of
vernacular languages and print capitalism.” 75 With print capitalism and
the emphasis of commonalities within a defined territory, people began
to believe that they were connected with others unknown to them. 76
Similarly, the census provides data to the public which emphasizes
similarities of a collective and political social body, and strengthens the
imagination of a connection between people spread over an enormous
territory. 77 The census is a composite picture of the nation as a whole,
giving a visual depiction and portraying its education, production,
lifestyle and economic patterns. 78
Statistics established a new
69. Mezey, supra note 64, at 1722 (explaining that the Chinese population began to
arrive in California approximately around the time of the gold rush).
70. See id. at 1729.
71. Id. at 1725.
72. Id. at 1702.
73. Id. at 1747; see Sharon M. Lee, Racial Classifications in the U.S. Census: 1890–
1990, 16 RACIAL & ETHNIC STUD. 75, 85 (1993).
74. Id. at 1748.
75. Id. at 1707 (identifying certain factors that contributed to the rise of nationality,
namely decreasing monarchical legitimacy); see BENEDICT ANDERSON, IMAGINED
COMMUNITIES: REFLECTIONS ON THE ORIGINS AND SPREAD OF NATIONALISM 16, 16–21
(Courier Companies, Inc. rev. ed. 1991)).
76. Mezey, supra note 64, at 1707.
77. Id. (citing MARY POOVEY, MAKING A SOCIAL BODY: BRITISH CULTURAL
FORMATION, 1830–1864 (University of Chicago Press 1995)).
78. Id. at 1712; see MARGO J. ANDERSON, THE AMERICAN CENSUS: A SOCIAL HISTORY
22 (Yale Univ. Press 1990).
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relationship between people, facts and data, and these categorical
interpretations push into existence this imagined average community. 79
C. The Census as a Catalyst in the Preservation of the White National
Identity
Through the accumulation of statistics and the rapid increase of
minority groups, the meaning of “Whiteness” is necessarily changing.
Society will have to redefine “Whiteness” and include Latinos if Whites
are to maintain a numerical majority. 80 History has demonstrated that
the United States is willing to redefine and reclassify race and ethnicity.
By redefining and broadly interpreting the meaning of “White,” the
racial category can become more inclusive and inflate those numbers.
Also by narrowly defining ethnicity and restricting its availability as a
census answer, the census will force people to identify themselves in
groupings that do not match their social perception and standing.
Due to the framing of questions and limited scope of the census,
Whites receive an inflated numerical advantage and perception. An
example of how the census can increase numbers in the White racial
category is through the formation and layout of questions on the
questionnaire. From the inception of the Hispanic ethnic question, the
“Other Race” category was the fastest growing racial category in both
the 1980 and 1990 census. 81 The Census Bureau reasoned that
Hispanics did not understand the race question. 82 It can be inferred that
in response to such increasing numbers in the “Other Race” category,
the Census Bureau relocated the ethnicity question on the questionnaire
in the 2000 census. 83 Instead of being Question 7, the ethnicity
question became Question 5, directly before the race question. 84 With
the relocation of the ethnicity question, the “Other Race” category
79. Id. (stating that governmental practices contribute to and often assist in the formal
categorization of populations of different heritage, culture, and socio-economic status); see
DAVID THEO GOLDBERG, RACIAL SUBJECTS: WRITING ON RACE IN AMERICA 29, 29–32
(Routledge 1997).
80. See Powell, supra note 10, at 1402.
81. Ian Haney Lopez, Race on the 2010 Census: Hispanics & the Shrinking White
Majority, 134 Daedalus 42, 47 (Winter 2005); see also U.S. CENSUS BUREAU, APPENDIX
E: FACSIMILES OF RESPONDENT INSTRUCTIONS AND QUESTIONNAIRE PAGES: YOUR GUIDE TO
THE 1990 U.S. CENSUS FORM 3 (1990), http://www.census.gov/prod/1/90dec/cph4/appdxe.
pdf [hereinafter 1990 Census Questionnaire].
82. Lopez, supra note 81, at 47.
83. Id. at 46.
84. Id.
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declined. 85 By manipulating the formation of the census, fewer people
will choose the “Other Race” category, and more Hispanics will
continue to fall within the Black/White binary classifications.
The numerical inflation of the White category also results from the
census’s inclusion of groups which are historically not perceived as
White; exclusion of non-White populations; and individual reluctance to
being considered Hispanic. For example, in the United States those of
Middle Eastern and Arab descent are not viewed socially as White, but
they are counted racially by the census as White, unless there is a
different response to the ancestry question. 86 As noted above, the 3.8
million Puerto Ricans living on the Island of Puerto Rico are not
counted in the U.S census totals, which only incorporate the fifty U.S.
states. 87 There are also a large number of Hispanics who do not fill in
the ethnicity question or even, surprisingly, identify as “Not-Hispanic.”
Among foreign-born persons,17.2% of those born in Spain, 4% of those
born in Central and South America, 50.5% of those born in Brazil, and
89.3% of those born in Portugal and the Azores, filled in “NotHispanic.” 88 By contrast, approximately 90% of foreign-born Puerto
Ricans, Cubans, and Mexicans, and 77% of foreign-born Dominicans,
selected the Hispanic ethnicity classification. 89
The statistics
demonstrate a divide between certain more and less populous Hispanic
sub-groups. This division would make the smaller groups more
susceptible to being separated from the larger Hispanic grouping and
included solely within the Black/White binary.
Along with the present system of inflating the White majority,
there have been census proposals that considered the removal of the
“Other Race” category. 90 One justification is cost savings. If the 2010
census is conducted the same way as the 2000 census, the cost may
reach up to $12.6 billion. 91 Trimming down the amount of questions
85.
86.
87.
88.
Id.
Standards for Classification supra note 38.
GUZMÁN, supra note 4, at 1.
JORGE DEL PINAL & DIANNE SCHMIDLEY, MATCHED RACE AND HISPANIC ORIGIN
RESPONSES FROM CENSUS 2000 AND CURRENT POPULATION SURVEY, U.S. CENSUS BUREAU
(2000), http://www.census.gov/population/www/ documentation/twps0079/twps0079.html
#_ftn12.
89. Id.
90. See Rachel L. Swarns, Hispanics Debate Census Plan to Change Racial Grouping,
N.Y. TIMES, Oct. 24, 2004, at 1 (“Census officials are hoping to eliminate the option from
the 2010 questionnaire in an effort to encourage Hispanics to choose one or more of five
standard racial categories”).
91. Mary Mosquera, Census Counts on Handhelds to Cut Field Data-Gathering Costs,
GOVERNMENT COMPUTER NEWS, July 18, 2005, http://www.gcn.com/print/24_19/363511.html.
172
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and the minimization of printing might provide relief to the enormous
cost of the census. But by eliminating the “Other Race” category would
force Hispanics to choose one of the standard (i.e., Black/White) racial
categories. 92 Since 48% of Hispanics in the 2000 census 93 already
chose the White racial category, removing the “Other Race” category
would presumably inflate those numbers further.
D. Will History Repeat Itself and Re-Define Race and Ethnicity in
Efforts to Preserve the White American Identity?
Since race is subject to being defined and re-defined, the census
recognizes its fluidity; societal influence has altered and will continue to
change racial classifications. 94 Because of the rapid growth of the
Latino community, the fastest way to secure a numerical “White”
majority would be through the inclusion of Latino groups. 95 Racing “is
not a passive recognition of natural qualities, but rather the sum of
intentional actions taken to stratify the population in order to maintain
White privilege and non-White subordination.” 96
Will history repeat itself? Yes, it will. The census has been
gradually pushing Hispanics into the White racial category. The census
recognizes that race is socially constructed, yet Hispanics have no
separate racial category. 97 In the 2000 census, 42% of the Hispanic
population perceived themselves as a separate race. 98 Hispanics are
only recognized through ethnicity—theirs is, in fact, the only ethnicity
acknowledged by the census. 99 Recognizing Hispanic identity as
“ethnicity” rather than race, and then requiring Hispanics to choose a
recognized race, will force Hispanics to fall in line with the traditional
Black/White binary. The census refuses to recognize Hispanics as a
race and states that Hispanic recognition as a separate race is based
upon the respondents’ “confusion” or failure to understand the race
question. 100 In 1970, respondents who wrote in Hispanic, Mexican,
Cuban, or Puerto Rican in the “Other Race” category were reclassified
92. Id.
93. GREICO & CASSIDY, supra note 12, at 10.
94. Powell, supra note 10, at 1400–01 (explaining that the lack of a definitive Hispanic
category is likely due to the different categorizations these populations have been placed in
by previous U.S. Cenus).
95. Id. at 1405–06.
96. Id.
97. See Questions and Answers, supra note 57.
98. HISPANIC ORIGIN, supra note 11, at 10.
99. CENSUS 2000, supra note 33, at 2.
100. Lopez, supra note 81, at 5.
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and tabulated as White, literally forcing these individuals into
“Whiteness.” 101 Either through clever manipulation in questioning,
order of questions, or even through force, history is slowly repeating
itself.
IV. LATINO SUSCEPTIBILITY TO INCORPORATION INTO THE BLACK WHITE
BINARY
A. The Latin American Preference For White Identification
Latinos are the product of an invading culture, of imperialism. 102
Due to the mixing of races and the inclusion of race-based ideologies, a
color line was created and has been preserved within the Latino
community. 103 The traditional hierarchy that exists is Whites on top,
second “blended people”, third pure brown and then Black. 104
The ideology ingrained within the society of many Latin American
countries is that White purifies all (blanqueamiento)—the opposite of
the American “one-drop” ideology of color. 105 Under the “one drop
rule,” one drop of Black blood would essentially make that person
Black, regardless of phenotype. 106 The “one drop rule distinguishes
between contamination and purity, with there being no amount of
‘Whitening’ to repair contamination by Black or ancestral blood.” 107 In
Latin America the rule is reversed: a drop of White blood directs the
101. CAMPBELL GIBSON & KAY JUNG, U.S. CENSUS BUREAU, HISTORICAL CENSUS
STATISTICS ON POPULATION TOTALS BY RACE, 1790 TO 1990, AND BY HISPANIC ORIGIN,
1970 TO 1990, FOR THE UNITED STATES, REGIONS, DIVISIONS, AND STATES, WORKING PAPER
SERIES NO. 56, POPULATION DIVISION (2002), http://www.census.gov/population/www/docu
mentation/twps0056.html.
102. Larry Cata Backer, Not a Zookeeper’s Culture: LatCrit Theory and the Search for
Latino/a Authenticity in the U.S., 4 TEX. HISP. J.L. & POL’Y 7, 8 (1998).
103. Id. at 23, (explaining the difference in treatment of individuals based on heritage,
culture, and socio-economic status); see Jameelah S. Muhammed, Mexico, in NO LONGER
INVISIBLE: AFRO-LATIN AMERICANS TODAY 163–64 (Minority Rights Group eds. 1995).
104. Id.
105. Tanya Katerí Hernández, “Multiracial” Discourse: Racial Classifications in an
Era of Color Blind Jurisprudence, 57 MD. L. REV. 97, 121–23 (1998). “Latin American
race relations are a poor model to emulate. Id. at 133. The recognition of a separate class of
mixed race persons in Brazil has not led to a genuinely color-blind society, because the
desire to avoid being categorized with a denigrated Black populace has resulted in a hyperconsciousness of color gradations and phenotypical traces of African ancestry. Id. at 134.
In fact, Brazilians describe their race relations as ‘veiled apartheid.’” Id.
106. Neil Gotanda, A Critique of “Our Constitution is Color Blind,” 44 STAN. L. REV. 1,
26 (1991).
107. Id.
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person towards “Whiteness,” and allows that person to identify himself
or herself as White. 108
The Latin American ideology is evident through various statistical
reports demonstrating that Latinos perceive themselves as White. In the
U.S. census, prior to asking Latinos whether their origins were
Mexican, Puerto Rican and Cuban, 95% of Latinos self identified as
White. 109 In Puerto Rico in the 1950’s, 79.7% of the population
perceived themselves as White. 110 Half a century later, in the Puerto
Rican 2000 census, 80.5% of the population self-identified as White. 111
“The race data was viewed as inherently suspect because a visual
inspection of the population” did not comport with the national
image. 112 It may be inherently suspect under the American view of
race, but not under the Latin American ideology.
Within Latin America the hierarchy between those of different
pigment continues to be a prominent societal structure. Latinos with
White ancestry would find themselves at the top of the hegemonic
hierarchy in their countries of origin. 113 Blacks in Mexico continue to
be a marginalized group and the least represented. 114 Brazil continues
to recognize a “separate class of mixed race persons . . . [and maintains]
a hyper-consciousness of color gradations and phenotypical traces of
African ancestry.” 115 These views have existed in Latin America for
some time and persist amongst those living within the United States.
B. The Census’s Use as an Inclusionary Tool Pushes Minority SubGroups to Lobby for Their Own Identifier
A majority of Latinos prefer to identify themselves racially as
Latino, and to be distinguished from Whites, African-Americans and
Asians. 116
Some Latinos further prefer to identify themselves
separately from other Hispanic groups. Since the census is the “grand
108. Berta Esperanza Hernandez-Truyol, Building Bridges III – Personal Narratives,
Incoherent Paradigms, and Plural Citizens, 19 CHICANO-LATINO L. REV. 303, 317 (1998).
109. See id.
110. Hernández, supra note 5, at 1104.
111. Id.
112. Id.
113. Backer, supra note 102, at 8 (citing Church of Lukumi Babalu Aye v. Hialeah, 508
U.S. 520, 113 S. Ct. 2217 (1993)).
114. Id. at 8–9 (citing JAMEELAH S. MUHAMMED, MEXICO, IN NO LONGER INVISIBLE:
AFRO-LATIN AMERICANS TODAY 163, 164 (Minority Rights Group eds. 1995)).
115. Hernández, supra note 105, at 133–34.
116. MOLLYANN BRODIE ET AL., PEW HISPANIC CENTER & THE KAISER FAMILY
FOUNDATION, 2002 NATIONAL SURVEY OF LATINOS, PEW HISPANIC CENTER & THE KAISER
FAMILY FOUNDATION 23 (2002), http://pewhispanic.org/files/execsum/15.pdf.
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prize” in solidifying a recognized identity in the United States, 117 there
is plenty of identity politics and multiculturalism at play. 118 Many
groups would like to see a separate Hispanic or Latino racial category or
a more specific identifier of their sub-Hispanic group. The reasoning is
that “One function of official race classifications is to create a sense of
group membership or even community where there had been none
before.” 119
C. The Role of Law
Legal history has shaped and defined Latino identity within the
United States. Many other structures, such as the census, follow the
court’s lead. The courts began taking notice of Latinos in 1848, in the
Treaty of Guadalupe Hidalgo between the United States and Mexico. 120
The Treaty recognized people from Mexico as non-White. 121 It was not
until 1897 that a Texas federal court, in In re Rodriguez, was forced to
revisit the question of whether or not Mexicans were White. 122 Federal
naturalization laws during this time allowed only White aliens to
become U.S. citizens. 123 Due to political pressure from Mexico, and
treaties between the two countries that allowed Mexicans to become
citizens, the court found congressional intent and brought Mexicans
within the scope of the naturalization laws. 124 This meant that
Mexicans were allowed to become citizens precisely because they were
White. 125 In re Rodriguez demonstrates how racial classifications are
formed through the political process, and how political mobility
formulates society’s conceptions of what race means. 126
Despite the ruling in In re Rodriguez, there was still conflicting
precedent on how to determine whether a Hispanic was White. These
nineteenth and early twentieth century cases dealt mainly with mixedraced individuals. In In re Camille, the court found that a mixed-raced
117. Mezey, supra note 64, at 1748.
118. Id. at 1746.
119. Id. at 1703; see Lee, supra note 73, at 75, 85.
120. See Scott v. Sandford, 60 U.S. 393, 533 (1857).
121. See id.
122. See In re Rodriguez, 81 F. 337 (D. Tex. 1897); see also Kevin R. Johnson, Racial
Restrictions on Naturalization: The Recurring Intersection of Race and Gender in
Immigration and Citizenship Law, 11 BERKELEY WOMEN’S L.J. 142, 143 (1996).
123. Rodriguez, 81 F. at 337.
124. See id. at 350–55.
125. Id. at 354–55.
126. George A. Martinez, Teaching, Scholarship and Service: Practicing LatCrit
Theory: The Legal Construction of Race: Mexican-Americans and Whiteness, 2 HARV.
LATINO L. REV. 321, 326–27 (1997).
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child with a White Canadian father and an Indian mother was not
White, and could not be naturalized. 127 In 1912, the court found that a
mixed-raced child of a White German father and a Japanese mother was
not “White” within immigration law. 128 This posed problems for
Mexicans who were “mixed” with Spanish and indigenous blood. 129 It
also gave the United States the ability to deny citizenship and other
rights.
In 1935, the U.S. Supreme Court found that the state courts in
Texas routinely excluded Mexican Americans from serving on juries
based on their “race.” 130 Yet in 1952, the Texas courts concluded that
Hispanics were White, and thus that there was no discrimination when
Hispanics were excluded from the jury because such exclusion was not
based on race! 131 In the same year, the U.S. Supreme Court found that
“Persons of Mexican descent” are a cognizable group and are protected
by the Equal Protection clause from local discrimination. 132 On the
other hand, the courts also found that for purposes of a class action suit,
the term “Mexican American” failed to define a class within Federal
Rule of Civil Procedure 23. 133 Overall, Latinos are defined as White
under the law, but it matters whether or not an individual is mixed with
the other standard U.S. racial categories.
V. LATINOS WILL NOT BENEFIT FROM BEING CLASSIFIED AS “WHITE”
A simple change of classification does not erase a past filled with
discrimination, stereotypes, and stigma. In 1848 the United States
promised all Mexicans remaining in the U.S. full citizenship rights, but
virtually taxed and licensed them out of existence within the political,
economic and social infrastructures. 134 During the Gold Rush there was
an onslaught of lynchings and murders, in efforts to force Mexican
Americans to release any mining claims they may have had. 135
Congress also recognized and expressly stated that Latinos are isolated
from the political arena and have long been targeted in efforts to
127. See In re Camille, 6 F. at 256–57 (Or. Ct. App. 1880).
128. See In re Young, 198 F. 715, 716–17 (D. Wash. 1912).
129. Martinez, supra note 126, at 327.
130. Norris v. Alabama, 294 U.S. 587, 598 (1935).
131. Hernandez v. State, 251 S.W.2d 531, 536 (Tex. Crim. App. 1952).
132. Hernandez v. Texas, 347 U.S. 475, 477–79 (1954).
133. Lopez Tijerina v. Henry, 48 F.R.D. 274, 276 (D.N.M. 1969).
134. Yvonne Gonzalez Rogers, Reapportionment and Latino Political Power in
California In Wake of the 1990 Census, 5 LA RAZA L.J. 28, 32 (1992); see ACUNA supra
note 61, at 114.
135. Id.
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diminish their power. 136 To this day, Latinos are seen as a group which
bring an inferior culture into the United States and are prone to receive
welfare and commit crimes. 137 The welfare stereotypes continue to
exist even though Latino men are employed at a higher rate than any
other population group. 138 On television, between 2001 and 2002,
Latinos represented only 2% of primetime characters, which is far from
actual national population percentages. 139 A stereotype which continues
to exist and has transformed over time is that of the “Cholo,” used in the
U.S. in the late 1840’s meaning low-caste or a Mexican which is a half
breed and today as an uneducated Mexican American gang member. 140
Stereotypical perceptions and negative images continue to permeate
throughout the media and within society.
It is not hard to find a Latino. Having a Spanish surname is one
easy way of distinguishing whether or not someone is Latino. If an
individual is born with the last name Mendoza, unless he denies or
changes his last name, he will be classified as Latino, whether or not he
claims that group identity. Language use is another way in which
Hispanics can be identified. Many children born in the United States to
predominantly Spanish-speaking parents speak with an accent. A
person who can only speak Spanish, or has an accent deriving from a
Spanish-speaking country, will be classified as Hispanic. Physical
features can also give rise to whether or not someone is viewed as
Hispanic. A person with a darker tone to her skin or exotic facial
features may be characterized as non-White, and possibly Hispanic.
Simply because a person is classified as White, or has a fair
complexion, does not mean that she will be viewed or treated as White
within society.
Latinos are still perceived as a group which is distinct from the
White majority; because of this perceived difference, Latinos will
136. S. REP. NO. 94-295, at 24, 25 (1975). Nixon v. Kent County, 76 F.3d 1381, 1395
(6th Cir. 1996) (stating that “Language minority citizens, like Blacks throughout the South,
must overcome the effects of discrimination as well as efforts to minimize the impact of
their political participation ‘language minority citizens’ are defined as ‘persons who are
Asian American, American Indian, Alaskan Natives, or Spanish heritage.’”).
137. Richard Delgado, Rodrigo’s Bookbag: Brimelow, Bork, Herrnstein, Murray and
D’Souza-Recent Conservative Thought and the End of Equality, 50 STAN. L. REV. 1929,
1952 (1998).
138. See Laura M. Padilla, “But You’re Not a Dirty Mexican”: Internalized Oppression,
Latinos & Law, 7 TEX. HISP. J.L. & POL’Y 59, 62 (2001).
139. MCCRAE A. PARKER ET AL., MOTT C.S. FOUNDATION, FALL COLORS 2001–02 PRIME
TIME DIVERSITY REPORT 3, 22 (2002), http://www.eric.ed.gov/ERICDocs/data/ericdocs2sql/
content_storage_01/0000019b/80/1a/09/9f.pdf.
140. Sandrino-Glasser, supra note 59, at 115.
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continue to be discriminated against. For example, Latinos in
California are underserved by the legal profession at three times the rate
when compared to Whites. 141 Latinos, “despite their longevity in this
nation—continue to show the lowest college-going rates and the lowest
economic profile.” 142 In 1996, there was a higher percentage of Latinos
living in poverty than either the White or Black United States
population. 143 Since many Latinos can be clearly identified through
their surnames, possibly physical features, and accents, they can easily
be discriminated against.
Redefining Latino groups will also have an effect on the way
federal funds are allocated and affect the methods in collection data on
discrimination. More than $100 billion dollars are allocated each year
based on census data. 144 The data collected by the census on racial
enumeration has supplied the foundation for civil rights enforcement. 145
The Census Bureau collects data on race to fulfill a variety of
legislative and program requirements. Data on race are used in
the legislative redistricting process carried out by the States and
in monitoring local jurisdictions’ compliance with the Voting
Rights Act. These data are also essential for evaluating Federal
programs that promote equal access to employment, education,
and housing and for assessing racial disparities in health and
exposure to environmental risks. More broadly, data on race are
critical for research that underlies many policy decisions. 146
Redefining Latinos as White will immediately curtail civil rights
protections to a group which has already been historically
marginalized. 147 Therefore, it is imperative that Latinos maintain an
identity separate from that of Whites.
If Latinos are defined solely as White, they will not benefit from
the same privileges poor White communities did in the past. History
141. CALIFORNIA COMMISSION ON ACCESS TO JUSTICE, THE PATH TO EQUAL JUSTICE IN
CALIFORNIA 3, 3–9 (2002), http://calbar.ca.gov/calbar/pdfs/accessjustice/2002-AccessJustice-Report-Summary.pdf.
142. Brief of Latino Organizations as Amici Curiae in Support of Respondents, Grutter
v. Bollinger, 539 U.S. 306 (2003) (No. 02-241).
143. Patricia Palacios Paredes, Latinos and the Census: Responding to the Race
Question, 74 GEO. WASH. L. REV. 146, 162 (2005).
144. See Census.gov, Uses for Questions on the Census 2000 Forms, http://www.census
.gov/dmd/www/content.htm (last visited Oct. 12, 2008).
145. Mezey, supra note 64, at 1745.
146. ELIZABETH M. GRIECO, U.S. CENSUS BUREAU, THE WHITE POPULATION, CENSUS
2000 BRIEF, 10 (2001).
147. Paredes, supra note 143, at 148; see MATTHEW FRYE JACOBSON, HISTORY,
HISTORICITY, AND THE CENSUS COUNT BY RACE, IN THE NEW RACE QUESTION: HOW THE
CENSUS COUNTS MULTIRACIAL INDIVIDUALS 259 (Joel Perlmann et al. eds., 2002).
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demonstrates that there was an economic benefit to White communities
from the subordination of minority groups. With time, the privileges
and effects of slavery and segregation are very slowly diminishing.
Since Latinos make up some of the poorest communities in the United
States, the only effect of transferring their identity will be to turn a poor
Latino into a poor White. The difference is that this poor White will be
distinguishable by name, accent, and/or physical features, and continue
to be discriminated against based on these differences. There will be no
equality in the poor White communities when a former Hispanic, now a
poor White, is discriminated against because of his or her differences.
VI. CONCLUSION
Hispanics are the fastest growing community in the nation. If the
current definitions of race and ethnicity do not change, by 2050, Whites
will no longer be a statistical majority. History has shown that the
government is willing to redefine and reclassify racial groups for
political reasons. The question is not whether there will be a movement
to protect the White American identity—but rather what will the next
move be? Latinos are vulnerable to this identity inclusion because
within their countries of origin, a color hierarchy exists. Within the
Latino community there are many strong political factions. Will they
splinter in the hopes of solidifying a more concrete identity for their
own group or will they hold strong and accept a broad identifier? In all
it is obvious that, unless you look like you’re White, talk like you’re
White, and have a White last name, you will not be White. And if an
individual is a poor White, former Latino, with a Spanish surname, an
accent or Latino physical characteristics, that person will most likely
stay poor.