The Ju Toy decision held that the due process clause of the Fifth Amendment does not always require a judicial procedure for denial of benefits, even when a person claims to be a U.S. citizen. Congress, therefore, may authorize an executive department to make the final determination on a person’s claim to citizenship.
When Ju Toy arrived at the port of San Francisco, he claimed to be a U.S. citizen returning from a temporary visit to China. Immigration officials, however, rejected his claim of citizenship and denied him permission to enter the country. The ruling was upheld on administrative appeal by the secretary of commerce and labor. When Toy petitioned the U.S. district court for a writ of habeas corpus, his petition was rejected. In earlier cases, the Supreme Court had upheld a federal law authorizing executive departments to make the final determination concerning the admission of persons affected by the
Associate Justice Oliver Wendell Holmes, who wrote the majority opinion in United States v. Ju Toy.
By a 6-3 vote, the U.S. Supreme Court endorsed the district court’s decision. Writing for the majority, Justice
Aleinikoff, Thomas A., et al. Immigration and Citizenship: Process and Policy. 6th ed. St. Paul, Minn.: Thomson/West, 2008. Hyung-chan, Kim, ed. Asian Americans and the Supreme Court: A Documentary History. Westport, Conn.: Greenwood Press, 1992.
Chinese Exclusion Cases
History of immigration after 1891
Supreme Court, U.S.