The hardening of U.S. isolationism and nativism set the stage for the Supreme Court to affirm the 1790 Nationality Act’s prohibition against naturalization for Asians because they were considered racially not “white” regardless of their demonstrated acculturation and integration. Takao Ozawa was a graduate of a U.S. college living and working in Hawaii with his family. While he was otherwise qualified for naturalization and citizenship, his application for citizenship was rejected on the basis of his race. The next year in the case of Thind v. United States, the Supreme Court would contradict itself in applying a different standard of race in another case regarding Asian American citizenship.
“Mr. Justice Sutherland delivered the opinion of the court:
The appellant is a person of the Japanese race, born in Japan. He applied, on October 16, 1914, to the United States district court for the territory of Hawaii to be admitted as a citizen of the United States. His petition was opposed by the United States district attorney for the district of Hawaii. Including the period of his residence in Hawaii appellant had continuously resided in the United States for twenty years. He was a graduate of the Berkeley, California, high School, had been nearly three years a student in the University of California, had educated his children in American schools, his family attended American churches, and he had maintained the use of the English language in his home. That he was well qualified by character and education for citizenship is conceded . . . .
The language of the Naturalization Laws from 1790 to 1870 had been uniformly such as to deny the privilege of naturalization to an alien unless he came within the description ‘free white person’… Beginning with the decision of Circuit Judge Sawyer… the Federal and state courts, in an almost unbroken line, have held that the words ‘white person’ were meant to indicate a person of what is popularly known as the Caucasian race . . . .
The appellant in the case now under consideration, however, is clearly of a race which is not Caucasian, and therefore belong entirely outside the zone on the negative side . . . These decisions are sustained by numerous scientific authorities . . . We think these decisions are right, and so hold.”