Timeline

1922

October 3rd, 1922

In Ozawa v. United States, U.S. Supreme Court Upholds Law Banning Japanese Immigrants from Becoming Citizens

Beginning in 1790, the immigration laws of the United States limited naturalization to free white immigrants. In 1870, Congress passed a revised immigration law that allowed for the naturalization of immigrants of African descent, but in 1882, Congress passed the Chinese Exclusion Act, which forbade the naturalization of Chinese immigrants.

After the passage of the Chinese Exclusion Act, the naturalization eligibility of other Asian immigrant groups was unclear. In 1914, Takao Ozawa, a Japanese-American who had lived in the United States since the age of nine, filed a petition for naturalization. When his petition was denied, he challenged the denial in court and his case reached the United States Supreme Court in 1922. Oral arguments were held on October 3 and 4.

On November 13, 1922, the Supreme Court held unanimously that Mr. Ozawa and other Japanese immigrants were ineligible for American citizenship, on the basis that the Immigration Act of 1790 limited naturalization to free whites, and people of Japanese or other Asian descent did not qualify as white. In 1924, Congress passed a further revision to the immigration law that forbade all immigration from Japan and other countries in Asia. The ban on immigration from Asia and the naturalization of immigrants from Asia was not repealed until 1952. The 1952 law in turn imposed extremely restrictive national quotas on immigration from Asia, which were not repealed until 1965.