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October 3
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4
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1922
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November 13
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1922
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Takao Ozawa v United States
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260
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178
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43 S Ct 65 67 L Ed 199 1922 US LEXIS 2357
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1922
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Sutherland
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''unanimous''
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'',
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."
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.
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.
