Terrace v. Thompson
44 S. Ct. 15, 1923 U.S. LEXIS 2736, 263 U.S. 197 (1923)
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Rule of Law:
A state law prohibiting aliens who are ineligible for citizenship from owning or leasing agricultural land does not violate the Fourteenth Amendment's Equal Protection or Due Process clauses, as states have broad power to regulate land ownership based on classifications established by federal naturalization law.
Facts:
- The Terraces, who are U.S. citizens, own a tract of agricultural land in King County, Washington.
- Nakatsuka, a subject of the Emperor of Japan residing in Washington, is a capable farmer.
- The Terraces desire to lease their land to Nakatsuka for a five-year term for the purpose of farming.
- Nakatsuka desires to accept the lease from the Terraces.
- A Washington state law, the Anti-Alien Land Law, prohibits aliens who have not declared an intent to become citizens—a group that includes Nakatsuka, who was ineligible for citizenship—from owning or having an interest in land.
- The law imposes penalties for violations, including forfeiture of the land to the state and criminal prosecution.
- The Attorney General of Washington threatened to enforce these penalties against the Terraces and Nakatsuka if they proceeded with the lease.
Procedural Posture:
- The Terraces and Nakatsuka (appellants) filed a suit in the U.S. District Court to enjoin the Attorney General of Washington (appellee) from enforcing the state's Anti-Alien Land Law.
- The Attorney General filed a motion to dismiss the complaint on the grounds that it did not state a claim for equitable relief.
- The District Court granted the motion and entered a decree of dismissal on the merits.
- The Terraces and Nakatsuka appealed the District Court's decree to the U.S. Supreme Court.
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Issue:
Does a Washington state law prohibiting aliens ineligible for U.S. citizenship from owning, taking, or holding any interest in land for agricultural purposes violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment or conflict with the treaty between the United States and Japan?
Opinions:
Majority - Mr. Justice Butler
No, the Washington Anti-Alien Land Law does not violate the Fourteenth Amendment or the U.S.-Japan treaty. The Court reasoned that each state has the power to deny aliens the right to own land within its borders, a principle rooted in common law. The law's classification, which distinguishes between aliens eligible for citizenship and those who are not, is not arbitrary or a denial of equal protection because it is based on the reasonable classifications established by Congress in federal naturalization laws. The Court distinguished this case from those involving the general right to earn a living in common occupations, holding that the 'quality and allegiance of those who own, occupy and use the farm lands' is a matter of the highest importance to the state. Furthermore, the U.S.-Japan treaty grants rights to lease land for 'residential and commercial purposes,' but the enumeration of these specific rights implicitly excludes agricultural purposes.
Dissenting - Mr. Justice McReynolds and Mr. Justice Brandeis
These justices did not issue a formal opinion on the merits but stated their belief that there was no justiciable question involved and that the case should have been dismissed on that ground.
Analysis:
This decision upheld the constitutionality of Alien Land Laws, which were prevalent in western states and primarily targeted Japanese immigrants. It established the significant precedent that states could use federal naturalization categories as a basis for discriminating against certain classes of aliens in the context of property rights. By distinguishing land ownership as a state-regulated privilege rather than a fundamental right, the ruling gave states wide discretion to enact such discriminatory legislation. This precedent, while later repudiated and overturned by subsequent cases like Oyama v. California, represents a key moment in the history of constitutionally-sanctioned racial discrimination.
