Chy Lung v. Freeman
Chy Lung v. Freeman is a significant Supreme Court case from the 19th century that addressed issues of immigration law and state authority. The case arose when Chy Lung, a Chinese national, and twenty other women were denied entry into the United States by California immigration officials, who labeled them as "lewd and debauched." The state law required these women to post a substantial bond for their admission, which they were unable to pay. Consequently, they were detained by local authorities. The California Supreme Court upheld the constitutionality of the law, but the matter was escalated to the U.S. Supreme Court. In a unanimous decision, the Supreme Court declared the California statute unconstitutional, asserting that only Congress has the authority to regulate immigration. The Court emphasized that the state’s law not only exceeded its jurisdiction but also posed risks of international conflict. Ultimately, the ruling mandated the release of the detained women, marking an important moment in the interpretation of federal versus state powers regarding immigration.
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Subject Terms
Chy Lung v. Freeman
The Case: U.S. Supreme Court decision concerning the authority of the national government
Date: Decided on October 1, 1875
Significance:Based on principles of federalism, the Chy Lung decision put limitations on the extent to which the states might restrict the admission of persons into the country.
When Chy Lung, a subject of the emperor of China, arrived in San Francisco, immigration officials classified her and twenty other women as “lewd and debauched.” In order for the women to be admitted, California law required a bond of five hundred dollars in gold from each of them. Unable to obtain the money, and refusing to return to China, the women were held as prisoners in the custody of San Francisco’s sheriff. The state’s high court upheld the constitutionality of the statute.
The Supreme Court, however, ruled unanimously that the statute was “in conflict with the Constitution of the United States, and therefore void.” Writing the rationale for the decision, Justice Samuel F. Miller explained that Congress, not the states, was empowered to enact legislation concerning the admission of persons from other nations. Although states could make reasonable and necessary regulations concerning paupers and convicted criminals, this particular statute went far beyond what was appropriate, and it had the potential of embroiling the United States in quarrels with foreign nations. Its “manifest purpose,” moreover, was simply to obtain money. The Court ordered, therefore, that the women must be released.
Bibliography
Chang, Iris. The Chinese in America: A Narrative History. New York: Viking Press, 2003.
McClain, Charles J. In Search of Equality: The Chinese Struggle Against Discrimination in Nineteenth-Century America. Berkeley: University of California Press, 1994.