Terrace v. Thompson
Terrace v. Thompson is a notable legal case from 1921 that addressed the rights of alien residents in relation to land ownership and agricultural activities within Washington State. The case arose when Terrace, a Japanese farmer who was an alien, sought to lease land but was hindered by a state law prohibiting aliens from buying or selling agricultural land unless they had declared an intention to become U.S. citizens. This law, particularly impactful for Asian residents who were ineligible for naturalization, raised significant constitutional questions. Terrace contended that the law infringed on his rights under the Fourteenth Amendment and violated a treaty between the United States and Japan, which ensured equal trade rights for Japanese citizens.
However, the U.S. Supreme Court ultimately ruled against Terrace, stating that the state's police power allowed for regulation of agricultural land ownership and that this privilege did not extend to non-citizens. The Court differentiated between agricultural activity and trade, asserting that the law aligned with the treaty provisions. This case highlights the complexities of immigration, citizenship, and property rights in early 20th century America, particularly as they pertain to marginalized communities.
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Terrace v. Thompson
The Case: U.S. Supreme Court decision on immigrant rights
Date: Decided on November 12, 1923
Significance:A major setback for legally admitted immigrants from Asia, the Terrace decision upheld the validity of state laws prohibiting Asians from owning or leasing land for the purpose of agriculture.
In 1921, the Washington State legislature enacted a law that prohibited aliens from buying or selling land for agricultural purposes unless they had “in good faith declared their intention to become citizens of the United States.” The law, which was enforced by severe criminal sanctions, did not make any exception for Asian residents who were legally disqualified from becoming naturalized citizens. Terrace, an alien Japanese farmer wanting to lease land, argued in court that the law violated both the Fourteenth Amendment and a treaty with Japan that guaranteed the right of Japanese citizens to participate in trade on an equal basis with U.S. citizens.
The U.S. Supreme Court, however, rejected Terrace’s arguments. Although the Court in Truax v. Raich (1915) had recognized the constitutional right of a resident alien to earn a livelihood in a common occupation, it concluded that this right did not extend to “the privilege of owning or controlling agricultural land within the state.” The police power of the state included discretionary regulation of the “quality and allegiance” of persons who might exercise this important privilege that affected “the safety and power of the state itself.” Defining agricultural production as distinct from trade or commerce, moreover, the Court concluded that the law was not inconsistent with the applicable treaty.
Bibliography
Chuman, Frank. The Bamboo People: The Law and Japanese Americans. Del Mar, Calif.: Publisher’s Inc., 1976.
Hyung-chan, Kim, ed. Asian Americans and the Supreme Court: A Documentary History. Westport, Conn.: Greenwood Press, 1992.