Although the Panama Canal Zone was legal territory of the United States until the implementation of the Torrijos–Carter Treaties in 1979, questions arose almost from its inception as to whether it was considered part of the United States for constitutional purposes, or, in the phrase of the day, whether the Constitution followed the flag. In 1901 the US Supreme Court had ruled in "Downes v. Bidwell" that unincorporated territories are not the United States. On July 28, 1904, Controller of the Treasury Robert Tracewell stated, "While the general spirit and purpose of the Constitution is applicable to the zone, that domain is not a part of the United States within the full meaning of the Constitution and laws of the country." Accordingly, the Supreme Court held in 1905 in "Rasmussen v. United States" that the full Constitution only applies for incorporated territories of the United States.