Nishimura Ekiu v. United States
Nishimura Ekiu v. United States is a pivotal Supreme Court case from 1891 that addresses immigration law and due process rights in the United States. The case involved Nishimura Ekiu, a Japanese citizen who arrived in San Francisco with limited financial resources and without knowledge of her husband’s address, which raised questions about her eligibility for entry under the 1891 immigration law. This law mandated that individuals who could not support themselves financially could be denied entry to prevent them from becoming public charges. When immigration officials denied her admission, Ekiu sought legal recourse, arguing that this denial infringed upon her liberty without due process.
The Supreme Court ultimately upheld the decision of the immigration officials by an 8-1 vote, affirming both the constitutionality of the 1891 law and the authority of immigration officials in such matters. The majority opinion, delivered by Justice Horace Gray, emphasized that Congress had explicitly granted immigration officials the power to make final determinations on the admissibility of certain categories of aliens. This case highlights important themes in U.S. immigration policy, including the balance between state interests and individual rights, and reflects the historical context of immigration regulations during that era.
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Nishimura Ekiu v. United States
The Case: U.S. Supreme Court decision concerning habeas corpus petitions by aliens
Date: Decided on January 18, 1892
Significance:The Nishimura Ekiu decision recognized the constitutionality of a federal law that authorized immigration officials to refuse to admit aliens into the country, without any opportunity for habeas corpus relief. The ruling also ignored minor procedural mistakes by immigration officials acting in pursuance of the law.
Nishimura Ekiu, a female citizen of Japan, arrived at the port of San Francisco in 1891. When she was interviewed by immigration officials, she claimed that she was going to meet her husband, who was living in the United States, but did not know his address. Having only twenty-two dollars in her possession, she said that she would stay at a hotel until her husband called her. A recent federal law of 1891 required the U.S. Treasury Department to refuse admittance to several categories of persons, including persons without succifient financial resources to avoid becoming public charges. After officials refused to allow Nishimura into the country, she petitioned the district court for a writ of habeas corpus, claiming that denial of such relief would deprive her of liberty without due process of law.
The U.S. Supreme Court voted 8-1 to approve both the constitutionality of the 1891 law and the officials’ refusal to allow Nishimura to land. Writing the majority opinion, Justice Horace Gray concentrated on the wording of the relevant statute, which referred to the concurrent jurisdiction of the district and circuit courts. He concluded that Congress had clearly and explicitly authorized immigration officials within the Treasury Department to make the final determination for refusing admittance of the categories of aliens enumerated in the statute.
Bibliography
Galloway, Donald. Immigration Law. Concord, Ont.: Irwin Law, 1997.
LeMay, Michael, and Elliott Robert Barkan, eds. U.S. Immigration and Naturalization Laws and Issues: A Documentary History. Westport, Conn.: Greenwood Press, 1999.