Ozawa v. United States (1922)
In 1914, Takao Ozawa applied for citizenship, challenging a 1906 American law that limited naturalization to “free white persons,” “aliens of African nativity,” and “persons of African descent.” He had arrived as a student in 1894, graduated from a California high school, and attended the University of California for three years before joining a U.S. business firm in Honolulu. After his application was denied, he appealed to the U.S. District Court for the Territory of Hawaii (1916). The district court ruled that Ozawa was “in every way eminently qualified” for citizenship except he was not white and clearly not of African ancestry. He then appealed his case to the U.S. Supreme Court, where he presented his good character, his complete loyalty to the United States, and his adoption over 20 years’ residence of English and American culture in favor of his petition. He was, “at heart . . . a true American.” In its decision, however, the Court held that although the term white was more broadly conceived than Caucasian—taking into account, for instance, character traits that might be linked to race ethnicity—Ozawa clearly did not qualify for citizenship.