Did Texas reserve the right to secede when it joined the United States?

Yes. Texas holds the right to resume self-government, and that right doesn’t depend on any special clause in the 1845 terms. It rests on older and broader ground. The right was reserved at the founding and carries to every state equally, and Texans wrote it into the constitution they ratified on the same ballot that approved annexation.

What Texas brought into the union

Texas joined in 1845 as an independent country. Congress offered terms, and Texans accepted them through an elected convention and a vote of the people. Texas kept its public lands and its public debt, along with the right to divide into as many as four additional states, a clause Chase never mentioned in Texas v. White. The consent that made Texas a member was Texas’s own, and the right to resume self-government came with it. That right rests on ground Texas shares with every other state.

Three states reserved the right to resume their powers, and Congress accepted it

When the Constitution was ratified, three states put in writing that they kept the right to take back the powers they were delegating. Virginia, ratifying on June 26, 1788, declared that the granted powers “may be resumed” by the people “whensoever the same shall be perverted to their injury or oppression.” New York, on July 26, 1788, reserved that the powers of government “may be reassumed by the people, whensoever it shall become necessary to their happiness.” Rhode Island said the same when it ratified in 1790. Congress seated all three without objection. That silence was acceptance. The reservation became part of the constitutional bargain the whole country joined.

The Equal Footing Doctrine carries that reservation to Texas

Here is why a reservation made by Virginia in 1788 belongs to Texas in 1845. Every state enters the union on an equal footing with the original states, with the same rights and powers, no more and no less. The Supreme Court stated it directly in Coyle v. Smith (1911): this is a union of states “equal in power, dignity and authority.” You cannot have an original group of states holding a reserved right to resume self-government while every state admitted later is permanently locked in. That would not be a union of equals. Whatever Virginia, New York, and Rhode Island reserved, Texas holds in equal measure.

The Framers’ own framework treats the states as sovereign parties

This is not a strained reading. It is how the men who built the system described it. Madison wrote in Federalist 39 that in ratifying, each state “is considered as a sovereign body, independent of all others, and only to be bound by its own voluntary act.” A bond entered by a state’s own voluntary act is the act of a sovereign party, not the surrender of a subject. The states created the federal government. They did not dissolve themselves into it.

Texans wrote it into the constitution they joined under, and it’s still there

The same October 1845 vote that approved annexation approved a state constitution whose Bill of Rights opens: “All political power is inherent in the people, and all free governments are founded on their authority, and instituted for their benefit; and they have at all times the unalienable right to alter, reform, or abolish their form of government, in such manner as they may think expedient.” Texans carried that right into the union with them, in their own words. Article 1, Section 2 of today’s Texas Constitution still declares that “all political power is inherent in the people” and that they have “at all times the inalienable right to alter, reform or abolish their government in such manner as they may think expedient.” Some form of that language has appeared in every Texas constitution since the Republic in 1836 except the Reconstruction constitution of 1869, which dropped it, and the 1876 Constitution restored it.

The bottom line

The right to resume self-government was reserved at the founding and belongs to Texas on an equal footing with every other state. Texans wrote it into the constitution they ratified with annexation, and they have never given it up. It’s a bigger right than any single clause could have granted.