If the United States Supreme Court had wanted a precedent for deciding the insular cases it might have found one in Spain’s treatment of the St. Marys-St. Johns district in 1813. When brought face to face with the question of applying the Spanish Constitution of 1812 to that area, Governor Sebastian Kindelan of East Florida, like the United States Supreme Court a century later, decided that the Constitution did not follow the flag. Higher authorities supported the governor in his decision, which, as will be shown below, was a result of the “Republic of Florida” episode of 1812-1813.
Corbitt, D. C.
"The Return of Spanish Rule to the St. Marys and the St. Johns, 1813-1821,"
Florida Historical Quarterly: Vol. 20:
1, Article 4.
Available at: https://stars.library.ucf.edu/fhq/vol20/iss1/4