Wong Wing v. United States
Wong Wing v. United States is a significant Supreme Court case that addressed the implications of the Chinese Exclusion Act of 1882, which allowed for the deportation and imprisonment of Chinese individuals deemed illegal immigrants. In this case, Wong Wing and three other Chinese men were sentenced to imprisonment followed by deportation. However, the Supreme Court unanimously ruled that the imprisonment provisions of the Act violated the constitutional guarantees of due process. Justice George Shiras, Jr. emphasized that the protections of due process extend to all persons, not just citizens, highlighting that serious penalties require appropriate legal processes, including grand jury indictments and jury trials as outlined in the Fifth and Sixth Amendments. This ruling underscored the necessity of legal protections for all individuals, regardless of their immigration status, and resulted in the deportation of the petitioners without the imposed prison sentences. The decision reflects broader themes of justice and rights within the context of immigration law in the United States.
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Subject Terms
Wong Wing v. United States
The Case: U.S. Supreme Court decision on the deportation of noncitizens
Date: Decided on May 18, 1896
Significance:The Wong Wing ruling prohibited Congress from imposing criminal punishments on noncitizens without permitting them jury trials and other constitutional rights. At the same time, however, the decision reaffirmed Congress’s unfettered authority to mandate the deportation of aliens without jury trials.
The Chinese Exclusion Act of 1882 imposed deportation and imprisonment for a maximum of one year at hard labor for Chinese persons found guilty of illegally entering or residing in the United States. The law specified that a hearing was sufficient for sentencing, and either a judge or a U.S. commissioner was authorized to render the sentence. Soon after the law went into effect, a commissioner for the Circuit Court of eastern Michigan determined that Wong Wing and three other Chinese men were illegal immigrants, and he sentenced them to sixty days at hard labor to be followed by deportation to China.
The Supreme Court unanimously held that the imprisonment provisions of the legislation were void because they violated constitutional guarantees. Speaking for the Court, Justice George Shiras, Jr., emphasized that the necessity for due process applied to “persons,” not simply citizens. Although Congress had the authority to legislate the deportations of aliens without jury trials, when the issue was punishment for an infamous crime, principles of due process required a grand jury indictment and a jury trial, as well as the other provisions in the Fifth and Sixth Amendments. Justice Stephen J. Field wrote a concurring opinion. The four Chinese petitioners, therefore, were deported without first having to serve a prison term.
Bibliography
Hyung-chan, Kim, ed. Asian Americans and the Supreme Court: A Documentary History. Westport, Conn.: Greenwood Press, 1992.
McClain, Charles J. In Search of Equality: The Chinese Struggle Against Discrimination in Nineteenth-Century America. Berkeley: University of California Press, 1994.