Ozawa v. US (1922) and Thind v. US (1923)
In these two cases, the Supreme Court ruled that race could be used to deny citizenship, in accordance with the Naturalization Acts of 1790 and 1870.
The Supreme Court case Ozawa v. The United States found Takao Ozawa ineligible for naturalization due to his race. Although Ozawa had been born in Japan, he had lived in the United States for twenty years. Ozawa’s application for citizenship was denied solely on the basis of race, as described in the 1790 and 1870 Naturalization Acts, which allowed only “free [W]hite persons” and those of “African nativity or descent” to become naturalized. This case was decided in the midst of increasing isolationism and nativism in the U.S.
Three months later, a Sikh immigrant from India was also denied citizenship on the basis of race in another Supreme Court ruling, Thind v. US (1923). In this case, the Court ruled that people of Asian Indian descent were not considered White “in accordance with the understanding of the common man”. This decision was applied retroactively to Asian Indian immigrants who had claimed to be White. It resulted in the loss of citizenship status for about 50 Asian Indian immigrants between 1923 and 1927.
