Sei Fujii v. State of California Summary

  • Last updated on November 10, 2022

Ending a long legal struggle, California’s highest court struck down the state’s Alien Land Law as a violation of the equal protection clause of the Fourteenth Amendment. While the direct beneficiaries of the ruling were Japanese immigrants, it had the long-term impact of promoting the Civil Rights movement.

When World War II ended in 1945, the state of California continued to have its infamous Alien Land Law, which prohibited land ownership by aliens ineligible for citizenship. By that time, the law applied almost exclusively to immigrants from Japan. In the case of [c]Oyama v. CaliforniaOyama v. California (1948), the U.S. Supreme Court ruled that Fred Oyama, a U.S. citizen, had the equal rights to own land without having to explain why his father, a noncitizen, had purchased it in his name. The ruling, however, did not address whether noncitizens had a constitutional right to land ownership. During that same year, Sei Fujii, a first-generation immigration from Japan, purchased land in East Los Angeles in order to test the constitutionality of the law. When the state initiated an escheat action to take possession of his property, Fujii argued that the Alien Land Law was void because it violated the [a]Fourteenth Amendment;equal protection clauseFourteenth Amendment as well as the [a]United Nations CharterUnited Nations Charter.[c]Sei Fujii v. State of CaliforniaFujii,SeiJapanese immigrants;Sei Fujii v. State of CaliforniaCalifornia;Sei Fujii v. State of California[a]Alien Land Law of 1920 (California)[c]Sei Fujii v. State of CaliforniaFujii, SeiJapanese immigrants;Sei Fujii v. State of CaliforniaCalifornia;Sei Fujii v. State of California[a]Alien Land Law of 1920 (California)[cat]COURT CASES;Sei Fujii v. State of California[cat]EAST ASIAN IMMIGRANTS;Sei Fujii v. State of California

By a 4-3 vote, the California Supreme Court ruled in Fujii’s favor. Although the majority opinion rejected the relevance of the United Nations Charter, it determined that the law violated the equal protection and Due process protectionsdue process components of the Fourteenth Amendment. Applying a “most rigid scrutiny” standard of review, the court found the law to be arbitrary and unreasonable, because it “was not reasonably related to any legitimate government interest.” The state chose not to ask the U.S. Supreme Court to review the ruling. Four years later, California voters repealed the Alien Land Law in a referendum.[c]Sei Fujii v. State of CaliforniaFujii, SeiJapanese immigrants;Sei Fujii v. State of CaliforniaCalifornia;Sei Fujii v. State of California[a]Alien Land Law of 1920 (California)

Further Reading
  • Bosniak, Linda. The Citizen and the Alien: Dilemmas of Contemporary Membership. Princeton, N.J.: Princeton University Press, 2008.
  • Hyung-chan, Kim, ed. Asian Americans and the Supreme Court: A Documentary History. Westport, Conn.: Greenwood Press, 1992.

Alien land laws

Asian immigrants

California

History of immigration after 1891

Japanese immigrants

Oyama v. California

Supreme Court, U.S.

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