Takao Ozawa v. United States

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Takao Ozawa v. United States
Supreme Court of the United States
Argued October 3 – 4, 1922
Decided November 13, 1922
Full case name: Takao Ozawa v. United States
Citations: 260 U.S. 178; 43 S. Ct. 65; 67 L. Ed. 199; 1922 U.S. LEXIS 2357
Holding
People of Japanese descent are not white, and hence are not eligible for naturalizaton.
Court membership
Chief Justice: William Howard Taft
Associate Justices: Joseph McKenna, Oliver Wendell Holmes, Jr., William R. Day, Willis Van Devanter, Mahlon Pitney, James Clark McReynolds, Louis Brandeis, George Sutherland
Case opinions
Majority by: Sutherland
Joined by: unanimous

Takao Ozawa v. United States, 260 U.S. 178 (1922), 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 June 29, 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 the Japanese classified as "white."

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[edit] Opinion of the Court

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

[edit] Effects of the Decision

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, 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 Asian 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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