Takao Ozawa v. United States Case Brief Summary | Law Case Explained

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Takao Ozawa v. United States, 260 U.S. 178 (1922)

What does it mean to be a White person? This was the key question in Takao Ozawa versus United States, a 1922 case in which the Supreme Court considered whether the term White, as used in a naturalization statute, referred to race or to skin color.

Takao Ozawa was born in Japan and immigrated to California as a teenager. He graduated from Berkeley High School and attended the University of California before moving to Hawaii and getting married. Ozawa and his wife had two children, both of whom attended American schools. The family attended a Christian church and spoke English at home. By all accounts, Ozawa’s character was exemplary.

In 1914, after he lived in the U.S. for 20 years, Ozawa filed a petition to become a naturalized U.S. citizen. The district court denied his petition, reasoning that he met all the requirements for naturalization except for one; he wasn’t White. Under Revised Statute Section 21-69 , only free White persons and those of African nativity or descent were eligible to become U S citizens. The court held that because Ozawa was Japanese, he fell outside both categories and was therefore ineligible for citizenship.

Ozawa appealed to the Ninth Circuit, where he made two arguments. First, he asserted that the case was controlled not by Section 21-69, but instead by the Naturalization Act of June 29th, 1906. Ozawa reasoned that this statute, which prescribed the procedures to be followed by all aliens who sought naturalization, supplemented Section 21-69 and applied to non-citizens who were neither White nor African. Second, Ozawa argued that even if naturalization was limited to White persons and individuals of African nativity or descent, he was a light-skinned Japanese person and thus qualified as White for purposes of the statute. Before deciding the case, the Ninth Circuit certified two questions to the United States Supreme Court. First, did the two statutes, read together, limit eligibility for naturalization to White persons and individuals of African nativity or descent? And, if so, were Japanese people considered White for purposes of naturalization law?

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