Ozawa v. United States

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Takao Ozawa v. United States
Seal of the United States Supreme Court.svg
Argued October 3–4, 1922
Decided November 13, 1922
Full case name Takao Ozawa v. United States
Citations 260 U.S. 178 (more)
43 S. Ct. 65; 67 L. Ed. 199; 1922 U.S. LEXIS 2357
Court membership
Case opinions
Majority Sutherland, joined by unanimous

Takao Ozawa v. United States, 260 U.S. 178 (1922),[1] was a case in which the United States Supreme Court found Takao Ozawa, a Japanese man, ineligible for naturalization. In 1922, Takao Ozawa filed for United States citizenship under the Naturalization Act of 1906 which allowed white persons and persons of African descent or African nativity to naturalize. He did not challenge the constitutionality of the racial restrictions. Instead, he attempted to have Japanese people classified as white.

Opinion of the Court[edit]

Justice George Sutherland found that only Europeans are white, and therefore the Japanese, by not being European, were not white and instead were members of an "unassimilable race," lacking provisions in any Naturalization Act.

Effects of the Decision[edit]

On the same day, the Supreme Court reiterated its ruling in Takuji Yamashita v. Hinkle.[2]

Within three months, Sutherland carried a similarly disfavorable ruling on another Supreme Court case concerning another alien from a Sikh immigrant from Punjab region in India (then British India) seeking U.S. citizenship, United States v. Bhagat Singh Thind. The upshot of this ruling was that although all whites were considered Caucasian, all Caucasians were not necessarily considered white. (‘Caucasian,’ a term used by physical anthropologists at the time to also refer to people whose ancestry traced to the Indian subcontinent, was not used in common parlance to refer to white people.)

Both decisions had a deleterious effect on Asian Americans as a class, strengthening and re-affirming the racist policies of U.S. immigration laws. With successful judicial backing, policymakers passed more anti-Asian laws across the nation under the heavy lobbying by the burgeoning Asiatic Exclusion League. This trend continued until the civil rights movements of the 1960s.

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