Chang Chan v. Nagle
Chang Chan v. Nagle is a significant Supreme Court case concerning immigration law and its implications for families of U.S. citizens. The case arose after the Immigration Act of 1924 was enacted, which notably excluded foreign wives of American citizens from entering the country if they belonged to races that were ineligible for naturalization. Four U.S. citizens, all married to Chinese women, faced denial of entry upon their arrival in San Francisco on July 24, 1924. The Supreme Court, in a unanimous decision, upheld the denial, emphasizing the strict interpretation of immigration laws as set forth in the Act. Justice James Clark McReynolds articulated that the hardships faced by the individuals did not provide grounds to override the explicit terms of the law. This ruling highlights the complexities of immigration policy and its impact on family unity, particularly in the context of race and citizenship. The case is a historical reflection of the legal challenges that arose during a time of restrictive immigration policies in the United States.
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Subject Terms
Chang Chan v. Nagle
The Case: U.S. Supreme Court ruling on immigration law
Date: Decided on May 25, 1925
Significance:The Chang Chan ruling upheld the application of a law disallowing the entrance of some foreign wives of U.S. citizens.
The Immigration Act of 1924 contained a provision that excluded foreign wives of U.S. citizens from entering the country if they were members of a race ineligible for naturalization. Chang Chan, as well as three other native-born U.S. citizens, had married Chinese women in China prior to the law’s enactment. When the four young women arrived in San Francisco on July 24, 1924, they were denied permanent admission. The Supreme Court unanimously held that the women did not have the right to enter the country. In the majority opinion, Justice James Clark McReynolds examined the few exceptions in the law and concluded that none of them applied to this particular case. He wrote that the “hardships of a case, and suppositions of what is rational and consistent in immigration policy, cannot justify a court in departing from the plain terms of an immigration act.”
Bibliography
Hyung-chan, Kim, ed. Asian Americans and the Supreme Court: A Documentary History. Westport, Conn.: Greenwood Press, 1992.
LeMay, Michael, and Elliott Robert Barkan, eds. U.S. Immigration and Naturalization Laws and Issues: A Documentary History. Westport, Conn.: Greenwood Press, 1999.