“We may prate of the circumstances that lie around us, and even of ourself, but still keep the inmost Me behind its veil. To this extent and within these limits, an author, methinks, may be autobiographical, without violating the reader’s rights or his own.” –Nathaniel Hawthorne, The Scarlet Letter
AFTER my aunt died, I was left with the task of sorting through her personal effects. Among these was the Safe. It had been owned by my grandfather who died five years before my birth, and, while my grandmother was alive, was the source of many wondrous things—the smell of sandalwood and camphor, dark recesses of locked mystery, and a seemingly unending source of crisp dollar bills to be spent on toy soldiers, model ships, and comic books. In the harsh light of middle age, the safe was much smaller, and the supply of dollar bills long since exhausted. Among, however, my aunt’s lapsed insurance policies, old checking account statements, and stock certificates from failed oil wells was a small box in which was an aged, yellowed envelope that had, as the narrator of the Scarlet Letter had put it in a different moment, “the air of an official record of some long ago period past, when clerks engrossed their chirography on more substantial materials.” For me, like Hawthorne’s narrator, “There was something about it that quickened an instinctive curiosity.”
Undisturbed, I presume, since my grandmother’s death in 1973, the envelope contained the two documents that documented the bookends of her history of citizenship. The first, a certificate of Hawai’ian residence, no. 7576, dated 1 May 1901, listed her occupation as laborer while providing me with her earliest extant picture—at the age of almost 4. The second was her certificate of naturalization, no 4887931, dated 31 August 1940. What struck me were the dissonant characteristics of both documents. The first had a footnote that drove home the unsurprising realities of the Chinese Exclusion Acts. Written on the bottom of the certificate of residence were the words: “No Chinese Laborer, whether he should hold this certificate or not shall be allowed to enter any State, Territory or District of the United States from the Hawai’ian Islands.” The second, while providing a picture of my grandmother, an unquestionably Asian woman, and listing her former nationality as Chinese, indicated her color as white.
Fig. 1: Rose Quon Young, Certificate of Residence
Rose Quon Young Chu was born on 23 June 1897 in Pauoa Valley on the island of Oahu; her father Young Hee was a vegetable and hog farmer who had first immigrated to Hawaii in 1881. He returned to China in 1893, the same year as the overthrow of the Hawai’ian monarchy and came back to the islands with his wife Chang Lo. Ah Quon was one of six children; she had four brothers and a sister. Her entire life centered on the valley about a mile and a half from downtown Honolulu. She was educated briefly at the Royal School, the first public elementary school on Oahu, married in 1912 to a valley taro farmer, Chu Fook Ting had three children, two of whom survived to adulthood, died on 8 November 1973 at a small nursing home just outside the confines of the valley, and is buried in a cemetery on a ridge overlooking the valley. During the first forty-three years of her life, bounded by the walls of the valley in which she was born, married, gave birth to and raised her children, and nursed her dying husband, she was a citizen of three nations and was both Asian and white.
The coincidence of Ah Quon’s certificates of residence and naturalization, while unusual, is an American story. In ironic microcosm, it is a prism that reveals the convoluted interaction of imperialism and conceptions of race and gender in first half of the twentieth century. It lays bare the ways in which assumptions about race and gender changed as legal and institutional structures interacted with events to translate notions of Americanism into the concrete, bureaucratic reality of making citizens of aliens. Ah Quon’s history of citizenship is extraordinary only in its utterly ordinary nature—in the way that the majesty of the law and historical circumstances shaped the life of a single woman who was born, lived and died within the confines of a small piece of the United States of America.
Born in 1897 in Honolulu of Chinese parents, Ah Quon became a citizen of the Republic of Hawai’i. Had she emigrated from China, Hawai’ian naturalization would have been difficult but not impossible. Between 1838 and 1871, many Chinese men married native Hawai’ian women and were naturalized; but the increase in Chinese immigration over the course of the nineteenth century led to the rise of increasingly exclusionary Hawai’ian legislation. While the last Constitution under the monarchy in 1897 prohibited the naturalization of Asians; citizenship was still possible for those born in the Kingdom. Under the terms of the Organic Act, the joint resolution of Congress that formally annexed the Islands to the United States, she became, as did all other citizens of Hawai’i, a naturalized citizen of the United States. Had the initial treaty of annexation dated 16 June 1898, been ratified by the Senate, it would have taken effect one week before her birth in 1897, and she would have become a natural-born citizen of the United States.
Despite the language of the Organic Act, Ah Quon’s citizenship was still qualified. Her race made her an anomaly among Americans. Until 1870, only whites could become naturalized citizens of the United States. The ratification of the Fourteenth Amendment only rendered state-defined criteria for citizenship and their prohibitions against black citizenship anachronistic. Under the Fourteenth Amendment, it was possible to be a citizen of the United States without having to be a citizen of an individual state, but racial criteria still defined the processes of immigration and naturalization.
As early as 1882, the United States began to shut down Chinese immigration with the Exclusion Act which suspended for ten years the entry of laborers and expressly forbade the naturalization of Chinese. In 1888, Congress broadened the prohibitions against immigration to include all Chinese except government officials, teachers, students, tourists, and merchants, and in 1892 it renewed the amended legislation making the exclusions indefinite. Hawai’i, on the other hand, had looked to China to fill the demands of the descendants of American missionaries who needed workers for their sugar plantations. Annual immigration of Chinese into Hawai’i leaped from 151 in 1871 to 1,283 the following year peaking in1896 and 1897 at 5,280 and 4,481 respectively. On the eve of US annexation, the Chinese in Hawai’i numbered 21,616 or nearly twenty percent of the Island’s population. The 1900 U.S. census reported that 84.4% (21,741 of 25,767) were foreign-born. What was especially problematic for the racial policies of the United States was the breach Hawai’ian annexation made in the barriers against Chinese immigration. Concern for these policies took priority over any consideration for the rights of the few Chinese who had become citizens under the terms of the Organic Act. Indeed, the initial treaty of annexation failed because a combination of California sugar refiners and the emerging beet sugar industry blocked ratification by pointing to the dangers that Chinese laborers would use Hawai’i as a gateway to the West Coast. Even worse, annexation, in the words of Champ Clarke (D, MO), meant the possibility of a “Chinese Senator from Hawaii, with his pigtail hanging down his back with his pagan joss in his hand [who] shall rise . . . to chop logic with George Frisbie Hoar and Henry Cabot Lodge.”
The Organic Act reconciled Hawai’i’s need for Chinese labor with the nation’s exclusionary racial and naturalization policies by requiring certificates of residence for all Chinese and restricting their movement into any other state, territory or district. Issued in 1901when she was four, Ah Quon’s residence certificate illustrated how the conceptions of race superseded rights of citizenship. Notwithstanding her constitutional right to seek the redress of grievances at the seat of government or “to pass and repass through every part of it [the United States] without interruption,” Ah Quon could not, or so her identity card declared, leave the Territory of Hawai’i.
Even if Ah Quon’s parents had mistakenly acquired an identification certificate for her, its existence denoted a general, legal presumption of her being an alien in her native land. The law and America in general had placed affirmative burdens upon the Chinese to prove they were citizens at a time when documentary evidence was minimal. Born at home, there was no direct evidence of her Hawai’ian birth other than the testimony of other Chinese who, for the most part were neither literate nor fluent in English, and presumptively and likely were aliens themselves. Ah Quon would subsequently need the certificate to document her later application for the issuance of a birth certificate. Second, if the prohibitions upon travel were inapplicable for Ah Quon, the existence of the certificate and presumption that she needed it underscored the burdens placed upon a four-year old to prove her possession of rights. Third, assuming the illegality of any restrictions on her movement, her right to travel was essentially a nullity in the absence of her parent’s rights to travel. Like the requirements of manumission papers for freed slaves, such burdens were the substantive denial of those rights.
The acquisition of the Philippines helped to modify the regulations on Chinese in Hawai’i. Because the Philippines had also become heavily dependent upon Chinese labor, the archipelago became an alternative source of illegal Chinese immigration. One major problem for Congress was that only the Chinese were expressly forbidden entry to the United States. Exclusion made no provision for the many Filipinos who may have been of mixed ancestry or, for that matter, ethnic Chinese who might be considered Filipino or Malay under the Bureau of Immigration and Naturalization’s existing systems of race classification. Extending the Exclusion Acts to cover immigration from the Philippines, the Congress also limited the rights of Chinese to travel between any possessions of the United States. Congress, did, however, distinguish between American citizens of Chinese ancestry and resident Chinese aliens when it repealed the restrictions on travel for the former.
The impact of the change, if Ah Quon were aware of it, was probably minimal. More significant to her status was her marriage to Chu Fook Ting on 7 December 1912. Ah Ting was older, 37, and a fairly well-off taro planter. His certificate of residence claimed residence in the islands since 14 June 1900. Like so many of his countrymen in Hawai’i, he had come from southern China as a contract laborer; but had by 1917 rented about twenty acres in the valley, placed it under taro cultivation, and operated a small poi factory leased from Jonah Kumalai, a local ukelele maker. The match was unusual for Hawai’ian Chinese because it was ethnically mixed: he Sze Yup; she Hakka or Keijiaren. At fifteen, Ah Quon had had an unusual amount of education especially for the daughter of Chinese immigrants: she had attended the Royal School, Hawai’i’s first public elementary school. Her parents owned a small farm on which they raised hogs and grew vegetables. Fook Ting was both literate and ambitious. By 1919, he not only had the farm, but was managing Kumalai’s poi factory and one of his own.
By marrying Fook Ting, Ah Quon lost her citizenship. The 1907 Expatriation law provided that any American woman who married a foreign national assumed his citizenship. In Ah Quon’s case, she became a citizen of the Republic of China, a status consistent with her ancestry. The legal theory upon which the law rested was that her citizenship had been suspended. Had she chosen, upon the termination of her marriage, she could theoretically “resume her American citizenship” if she continued to reside in the United States. The passage of the Cable Act in 1922 attempted to alleviate some of the ambiguities for women married to foreign nationals, but the law remained quirky and complicated their status. In brief, the law provided that effective upon its passage on 22 September, American women married aliens retained their citizenship and permitted those who had had their citizenship suspended or revoked to be naturalized regardless of their current status. The law, though, continued to deprive women of their citizenship if they married aliens racially ineligible for naturalization and to continue to bar women with intact marriages to them from resuming their American nationality.
Cable created a labyrinth of authority that created legal classes based upon time, race, and marital status that were at some points contradictory. While it removed the disabilities of gender for American women who had married blacks and whites after Cable’s passage, it continued to discriminate against all women married before it and those married to aliens racially ineligible for citizenship. In place of a relatively straight-forward categorical denial of citizenship to women married to aliens, the Act created six legal classes: 1) women who married before 22 September 1922, 2) women married after that date, 3) non-Asian women whose marriages to racially ineligible aliens had terminated, 4) non-Asian women married to aliens to racially ineligible aliens, 5) Asian women married to those racially ineligible for naturalization but themselves eligible for the restoration of their citizenship, and 6) Asian women married to those racially ineligible for naturalization. American women in class 1 were unaffected by their marriages. Classes 2 and 3 lost their citizenship but could reclaim it through naturalization providing they had committed no act of affirmative allegiance to a foreign power. Class 4 lost their citizenship but could be repatriated upon the termination of their marriages; class 5 could restored to citizenship if the women had been natural-born US citizens. Category 6, that in which Ah Quon and other Chinese-descended women born in Hawai’i prior the annexation of Hawai’i could not be naturalized because of the prohibitions of the Exclusion Acts. By using naturalization as the process for restoring or reviving a suspended citizenship, Cable effectively barred Asian women from ever becoming Americans again, but it also discriminated against white and black women as well.
The discrimination occasionally took on tragicomic proportions. Born of Chinese parents in 1898 in California and thus a natural-born citizen, Ng Fung Sing had returned to China with them at age five. In February of 1920, she married a Chinese who subsequently died. In April 1925, she returned to Seattle and sought admission to the United States to revive her citizenship. Unfortunately, she was barred from entry under the Exclusion Act on the grounds that she was a Chinese national. Ng had an additional problem not fully appreciated by the judge who believed she could appeal, if she had the resources, to the Supreme Court because he mistakenly believed that the Cable provisions did not apply to her and that she could be naturalized. In point of fact, because she was neither white nor black, she could not.
When seen through a racially discriminatory legal prism, Cable was not consistent. It allowed Asian women who married non-Asian aliens to retain their citizenship while it revoked it for white and black women who married Asians. It thus ironically sanctioned some interracial Asian marriages while discouraging others. Furthermore, it also encouraged all women not to report marriages to Asian husbands for fear it would result in the loss of their citizenship.
In 1931, Congress moved to rectify some of these contradictions. It ended the revocation of citizenship for those women with post-1922 marriages to ineligible aliens and allowed the repatriation of natural-born American women without regard for race. The amendments, however, rearranged the six old classes into three: 1) women regardless of color who married resident aliens, 2) non-Asian women who married aliens racially eligible for citizenship and then lived abroad, and 3) a small group of Asian and native Polynesian women born in Hawai’i prior to Annexation and American-born women of Asian descent who had been or were married to racially ineligible aliens. Class 1 retained their citizenship; class 2 could be repatriated upon their return to the United States; class 3 was barred from the restoration of their citizenship.
The amendments created new, deeper contradictions within the law. One amendment decreed that no woman who was a citizen at birth could be “denied naturalization . . .on account of her race.” This posed a twofold difficulty. First it brought Cable into direct contradiction with the Naturalization Act of 1870. The implication of the clause suggested that Cable could not revoke the citizenship of native-born Asian women who married ineligible aliens after1922. Even if this were the intent, as long as the operating theory of Cable was the suspension of one’s citizenship, a native-born Asian woman in the amended category 3 presumably should be able to restore or revive her citizenship upon the termination of her marriage to a racially ineligible alien. This would seem to be the intent of this language when seen in context with the original classes of Cable. The second problem spoke specifically to a very small class with consequences for Ah Quon. Because of the peculiar circumstances of Hawai’i’s legal history, Asian and Hawai’ian widows who were born before annexation and had never left the Islands could not be restored to citizenship. Cable’s provision for repatriation presumed the restoration of women to their original citizenship status. As neither white nor black these women could not be restored to their original citizenship status, that is naturalized under the Organic Act, because courts had been clear on the prohibition of naturalizing Asians because of the Exclusion Act.
Congress attempted to deal with the contradiction the next year by addressing the status of native Polynesian women in Hawai’i; it eliminated the distinctions between native and naturalized status and declared women born in Hawai’i prior to 14 June 1900 citizens at birth if they had resided in the United States at the time the resolution became law, 2 July 1932.  Debate on the House floor, little as there was, signified dissembling on the part of the Hawai’ian territorial delegate, a complete breakdown in the flow of information to the Committee on Immigration and Naturalization, or the way in which legislation often has unintended consequences. Albert Johnson(R-Wash), the Chair of the Committee reported to the House that the bill simply applied to “a dozen old Hawai’ian women who were born before annexation and who since the Cable Act of 1922 have no status for naturalization to which they were entitled.” Responding to William H. Stafford’s (R-Wisc.) question, Victor Houston, Hawai’i’s non-voting territorial delegate pointed out that they were neither white nor African and had been caught in the interstices of the law. Victor Kaleoaloha Houston personified the constituency ostensibly affected by the bill—that nexus of Navy, white (in Hawai’ian haole), and Hawai’ian ali’i (or aristocracy) that provided the core of the Islands’ elite in the twenties and thirties. Houston was the son of a rear admiral, educated in German and Swiss schools and had attended Annapolis. He retired as a commander and was elected territorial delegate in 1927. His mother was part-Hawai’ian and related to his wife.
The law, in fact, cast a much wider net because of the ways in which constructions of race, local politics and immigration intersected. Houston and Johnson’s concern for the “dozen old Hawai’ian women” did not comprehend the difficulties of translating the ambiguities of the island’s multi-racial mix to the legal processes of naturalization. If they were, responding to the simple matter of a few of Houston’s native Polynesian constituents, the realities of Hawai’ian life broke down the expectations of the clear racial categories, used by Congress, census takers, and immigration and naturalization authorities. The 1930 census indicates a far wider pool of beneficiaries listing 1,568 divorced and widowed women who were Hawai’ian, Asiatic-Hawai’ian [sic], Caucasian Hawai’ian and 562 Chinese. Conceivably this pool might have only netted a dozen women, but the creation of the class was determined not by women but the number of racially ineligible men who married American citizens. Sixty-two percent (29,077 of 46,902) of all married Asian men in 1930 were over the age of 34 and presumably not born in Hawai’i. In 1920, nearly 83% (9,309 of 11,223 of all Chinese and 96.2% (35,165 of 36,548) of Japanese men over the age of 21 were foreign-born. Finally, the legislation favored not the aged, but a cohort of women, like Ah Quon, born in the closing years of the Hawai’ian Republic in their mid-thirties that would increase as time passed. There were 1,820 married Chinese women in Hawai’i under 35 in 1930, who, because of exclusion, likely Hawai’ian-born and, thus, provide the pool of women who had lost their citizenship and who would be eligible to be repatriated once their marriages had terminated.
Since most immigrants from Asia prior to the enactment of the Chinese Exclusion Acts were Chinese, the broadly defined racial categories used by the Supreme Court made the Naturalization Act of 1907 easy to administer. With the acquisition of the Philippines and the introduction of immigrants from Central Asia, the presumptions of racial categorization became far more complex in the twenties and thirties. The exceptions sought for native Polynesian women by Houston represented one pole arguing for acceptance; the cases of John Ali and Palo, the need to find legal definitions of exclusion. Decided eight months apart in 1925 in two United States District Courts in different circuits, the racial definitions in Ex Parte Palo and United States v. Ali were in direct conflict. Palo, born in the Philippines in 1898 the illegitimate son of a Chinese father and Filipino mother, applied for entry into Washington state holding a US passport. Technically, because the Philippines were an unincorporated territory, its residents were American nationals—owing permanent allegiance to the United States and to be protected by its government— but decidedly not citizens of the United States. Held pending deportation, Palo filed an appeal with District Court Judge Jeremiah Neterer asking for his release and to be allowed entry into the United States. Neterer denied the request finding that Palo came under the prohibitions of the Chinese Exclusion Act. Palo, he explained, was an exception to the Common Law rule that “a native is a person born within the jurisdiction and allegiance of a country.” Palo was not Filipino or an American national but racially Chinese and, thus, could be denied entry.
Decided eight months later in a Michigan District Court, Ali illustrated diametrically contradictory reasoning. Four years earlier, Ali had been granted a certificate of naturalization on the grounds he was high caste Hindu making him part of the Indo-Aryan language group and therefore Caucasian and eligible for naturalization. The Bureau of Immigration and Naturalization filed suit to revoke Ali’s citizenship arguing that he was in a prohibited class. Before Judge Arthur J. Tuttle, Ali shifted the ground of his argument claiming that he was Muslim and thus descended from Arab traders to the Indian sub-continent and part of a racial group that clearly was eligible for naturalization. Either he was Indo-Aryan or he was Arab and of African descent. Finding Ali’s claims without merit, that the issue was not genetics by the land of origin. Citing a 1923 case, not used in Palo, the United States v. Bhagat Sing Thind, that “white persons” were to be interpreted in the light of common speech and not of scientific or genetic definitions. Borrowing heavily from the language in Thind, Tuttle wrote,
while it might be true that “the blonde Scandinavian and the brown Hindu” and a common ancestor “in the dim reaches of antiquity,” the average man knows that “there are unmistakable and profound differences”. . . No reason has been suggested and I can discover none why the mere fact that the early ancestors of the defendant came to India from Arabia where they had been called Arabians renders the defendant a white person. His skin is certainly not white, but unmistakably dark like that of the other members of his race.
The changeable nature of racial definitions represented in Ali and Palo were consistent with the status of American women married to foreign nationals. Cable’s primary concern had been to clarify and resolve the status of American women who had married foreign nationals, but because it approached this problem with generally European women in mind, racial categories came as an afterthought, to be wielded to be consistent with other exclusionary policies. In addition to its failure to reconcile the contradictions associated with American-born women of Asian descent, Cable had not dealt with women who had married non-Asian aliens before 1922. Trying to deal with the iniquity of the situation and address the racial inconsistencies in the 1931 amendments, amendments passed in 1936 eliminated the time distinction created by the 1922 original effective date of the Act especially for women who had remained in the United States since their marriages. It decreed that native-born women could resume their citizenship by taking an oath of allegiance before a court exercising naturalization jurisdiction. It also repeated and clarified its revocation of citizenship for women married to aliens racially ineligible for naturalization but also provided specific language that allowed for the repatriation of women whose marriages had terminated.
With the elimination of the 1922 dividing date, it is conceivable that Ah Quon might have had a claim for the restoration of her citizenship arguing that as a native-born American—the conversion of her status under the Houston law—she could no longer be denied naturalization on the grounds of race. This would have pitted one part of Cable against its exclusionary clauses. The case of Dang Mew Wan Lum suggests some intriguing possibilities had someone pursued this line of reasoning. Dang petitioned for naturalization in 1937 based on facts similar to Ah Quon’s. Born in Hawai’i in 1894, she had married in 1910 to a Chinese national. After she obtained naturalization papers, the Bureau of Immigration and Naturalization filed suit for their revocation. Jeremiah Neterer sitting on assignment to the Ninth Circuit, denied Dang the certificate because she had not resided in the United States on the date of the passage of the Houston bill. Although Dang’s marriage was intact, a fact mentioned by Neterer in his opinion, he never implied that reason or the 1936 clause that restated the revocation of citizenship for those with intact marriages were sufficient grounds for denial. Ah Quon, because she had resided in the United States on 2 July 1932, by Neterer’s reasoning might have been eligible for repatriation.
Whatever the issues were in Dang, events in Europe reconfigured the status of Ah Quon and other similar situated women. In 1939, Samuel Dickstein (D-NY), the chair of the Committee on Immigration and Naturalization reported to the House an amendment to Cable directed at alleged injustices caused to women who had not left the United States and still lost their citizenship as a result of Cable. A Russian immigrant, Dickstein may have been responding to events in Europe and trying to broaden categories of citizenship to be more inclusive. He clearly did not seem to grasp the distinctions between pre- and post-Cable marriages, much less the evolution of the law since its inception in 1922. Responding to questions from Fred Crawford (R-Mich) a rancher and owner of beet sugar mills, Dickstein said that the amendment “deals entirely with American-born women who have lived here all their lives: who have never been out of the country. The moment an American woman marries an alien she automatically loses her American citizenship.” To correct this problem, Dickstein proposed the addition of the phrase “or who has resided continuously in the United States since the date of such marriage.” Meant to clarify the problem presumably of pre-Cable marriages to aliens, Dickstein’s solution had far reaching consequences for Ah Quon.
The Dickstein amendment reflected the haphazard way in which naturalization and repatriation had worked through the twenties and thirties for women. In the ebb and flow of the law’s discrimination against women who married racially ineligible aliens, the accretions of amendments by 1940 had come to rest upon a significant and fortuitous, for Ah Quon and similarly situated women, legal theory. In 1907, women who married aliens were presumed to have had their citizenship placed in a suspended state that could be revived upon the termination of the marriage. Cable terminated married women’s citizenship then restored it through the process of naturalization, of granting a condition then absent. Under Cable, women lost their American citizenship and stood in a position no different from other aliens, and their repatriation depended upon “full and complete compliance with all requirements of the naturalization laws.” Albeit their citizenship would return to the status quo ante their marriages, naturalization conferred, not resurrected, that status.
The amendments of the thirties, however, shifted the legal grounds upon which repatriation rested. While the discrimination remained against women married to racially ineligible aliens, the general presumption was that citizenship could not be lost unless there was a formal renunciation of allegiance to the United States before a court having naturalization jurisdiction. Women who had married racially ineligible aliens were technically in limbo, their citizenship was, in fact, suspended during the time of their marriages. Within this context the contradiction that prohibited discriminating against the rights of native-born American women reinforced the idea that the rights of American women of Asian-descent had been suspended during the time of their marriage. The 1936 amendments, not only eliminated the Cable’s time differentiation, it created new procedures for repatriation that did not require compliance with naturalization regulations other than an oath of allegiance before a court with jurisdiction. In effect, it gave preferential treatment to women whose citizenship had been suspended.
By treating marriage to an ineligible alien as an interruption in one’s citizenship and then legislatively dismissing the legal event that created it, Congress opened up the possibility of Ah Quon’s repatriation. The Dickstein amendment made this a reality. By adding the phrase for continued residence as an alternative condition for the restoration of citizenship rights, Dickstein had provided an alternative line of legal process for women in Ah Quon’s situation. The 1940 amendment essentially declared her marriage moot if she could establish continuous residence in the United States which made possible the revival of her rights as a natural-born citizen, a status conferred upon her by the Houston bill. The evidence of her continuous residence in the United States was, ironically, a deposition provided by her daughter, Rose Yee Moi, a native-born citizen of the United States.
Ah Quon’s last barrier to the restoration of her citizenship was not substantive but procedural. Under the 1936 amendments to Cable, she would have to file a petition for a certificate of naturalization, take the oath of allegiance before a court with naturalization jurisdiction, and have the petition approved and placed before a court of record or judicial tribunal. While the documentation her citizenship status was defined by naturalization procedures, Ah Quon’s status was not defined by its rules. Her citizenship had been suspended, not revoked and the new matrix of law now permitted her to revive a suspended condition. But negotiating the bureaucracy of the Immigration and Naturalization Service also required satisfying its rules which in turn had to satisfy legal requirements. No Chinese were allowed to be naturalized. Ah Quon was a member of a prohibited class—she was Chinese, and if she were issued a naturalization certificate in compliance with the amended Cable Act, it would be invalid on its face if it listed accurately, from the bureaucratic regulations, the racial category to which she should have been assigned. The issuing clerk’s dilemma was obvious and his solution faithful to the letter of the legislation and legal consistency. Rose Quon Young Chu, citizen of the Republic of China, wife of an alien racially ineligible for naturalization was issued her certificate on 31 August 1940. In the space denoting color, she is listed as white.
Pre-dating the repeal of the prohibitions on Chinese naturalization, Ah Quon’s certificate specifically lists “color” rather than race, but color was used to denote race not as a descriptive term for complexion. Earl Harrison, director of the INS, issued Instruction 177 to adjust the designation of race for immigration procedures because of the passage of the law that allowed the naturalization of Chinese in 1943. Field Offices were advised to use only the following classifications: “White, African or African descent, Filipino, Indian, Eskimo, Aleutian. Such designation must be made only by the use of one of these six terms. This instruction will not disturb in any way this present method of designating race in naturalization matters.”
Two months later, the window of opportunity provided to Ah Quon, a month after the death of her husband, Congress brought the disparate parts of the laws governing nationality, naturalization and repatriation together in the Nationality Act of 1940. A manifestation of the process of codification and bureaucratization brought about by Progressive and New Deal legislation, the Nationality Act was a bipartisan effort approved by the American Bar Association to deal with what were obviously confusing and conflicting laws. “Our naturalization laws” declared one congressman, had “grown up like Topsey, and they conflict and overlap, and there was a real necessity and has been for years, to straighten them out and codify them so that they can be made workable.” The process had taken four years, and both the Congress and administration had participated. The secretaries of state and labor and the attorney-general—Cordell Hull, Frances Perkins, and Homer Cummings respectively—participated and submitted endorsements. But the law also defined a more immediate concern on the eve of World War II about who owed allegiance to the United States and conversely who the nation was obligated to defend or who might use a more casual definition of allegiance for subversive purposes. With “the Old World . . .on fire,” argued John Nurdock (D-Ariz), “there is especial need to debar the dangerous and undesirable variety and deport that variety who are already here. American citizenship was to mean something. . . and it must not be too freely bestowed upon the unworthy.”
Under the new law, Ah Quon would not have been able to regain her citizenship. In loosening the criteria for women re-acquiring their citizenship, the law disfavored Asians by requiring repatriation through naturalization. Reacquisition of one’s citizenship required compliance with “all requirements of the naturalization laws.” In effect, the law had altered the legal premise upon which Cable had rested. Instead of suspending the citizenship of American women in the affected classes, the Nationality Act had specifically revoked it. While it made provisions for the return of their citizenship and in so doing made them a favored class, it was as candidates for naturalization. Their only claim to naturalization was their previous status. Once naturalized, their status would revert to that of native-born. But, as in the case of American-born Asian women, their previous status could not be restored through naturalization. Having lost their citizenship, federal law precluded their regaining it through naturalization. If Ah Quon’s marriage had been terminated, she would only be able to be naturalized if she were not Asian.
The rapidity with which Ah Quon acted saved her from the fate of other Asian women who were similarly situated within the Ninth Circuit. Shee Mui Chong Yuen applied for repatriation under the same set of facts as Ah Quon. Born in Hawai’i in 1903, she married a Chinese national in 1920, and resided in the United States continuously since her birth. She applied for naturalization on the same grounds as Ah Quon, the Bureau of Immigration and Naturalization endorsed it and forwarded it to the federal district court. Yuen, however, procrastinated, she submitted her petition in 1944. Judge J. Frank McLaughlin denied the application on the grounds that the Nationality Act had invalidated the preceding legislation and that by failing to come forward earlier had failed to invoke her rights. Ironically, because she had petitioned for naturalization after 1943, she could have qualified under the more difficult National Origins Act quotas. Wartime exigencies had altered American policy and convinced Americans that the continued exclusion of Chinese from citizenship played into the hands of the Japanese who spared few efforts to point out America’s exclusionist policies. The Pacific War had produced good Asians and bad, and it became more convenient to allow Chinese to become citizens.
On an operational level, Ah Quon’s success at repatriation raises two significant unanswered questions. First, how was knowledge of a highly intricate and technical legal process shaped by distant and somewhat unrelated political pressures assimilated and transmitted throughout the community of Hawai’ian Chinese. How did the wife of a dying taro farmer whose children were high school graduates in their early twenties divine the intricacies of married women’s citizenship law, submit a petition for naturalization, and take her oath of allegiance in under two months? Further which circumstance was the more typical, Ah Quon’s or Yuen’s? Either answer would illuminate profoundly both the relationship of immigrant communities to the law and larger society and the ways in which information flowed through Hawai’i’s Chinatown.
Second, to what extent was there a substantial bureaucratic adjustment that resolved the conflict of law. Ah Quon’s repatriation was not an isolated event, six other women of Chinese descent, a woman with a Japanese married name were also repatriated on the same day. The Amended Repatriation Act became law on 2 July; her petition was submitted on 27 August and was sworn on 31 August. Presiding over the swearing-in ceremonies was J. Frank McLaughlin, the assistant U.S. attorney in Dang and the presiding judge in Yuen. McLaughlin had to have been aware of the law and, as would seem apparent, had an extremely narrow construction of its ascription of rights. In Yuen, McLaughlin took special pains to strike down the INS’s loose construction of Yuen’s status. He specifically invalidated the Service’s position that “persons who came within the provisions of the 1936 Act as amended, but who fail to take advantage of it during its existence are nevertheless deemed citizens.
While a definitive conclusion on this point awaits a systematic review of petitions submitted during the period July-October 1940 from Asian women in Ah Quon’s situation, her naturalization papers indicate a clerk’s and a court’s accommodation to the conflict in the law by the reconstruction of her race. In Ah Quon’s case, the fact of her race as a matter of law had been rendered moot, but the requirements of documenting her new status, a naturalization certificate, could not avoid an evaluation which, if answered truthfully, invalidated the process. Reconstructing her race, making her white instead of Chinese reconciled these two conflicting laws.
Ultimately though, at its heart, Ah Quon’s story is one revealing the intersections of different constructions of gender, citizenship and race. Only women lost their citizenship for the ordinary act of marrying. Women whose marriages crossed national borders were at risk, and only Asian women were at risk for the irretrievable loss of their citizenship. When the criteria for inclusion became inconvenient or inconsistent, the legalisms were altered to reconstruct who was presumptively entitled to constitutional protections. What was never assumed in the many cases of women similarly situated to Ah Quon was the presumption that rights existed independently of race and gender. Why did men not lose their citizenship when they married aliens, and why was the Fourteenth Amendment not construed to bring Asians under its protection? The presumptions that governed the status of women and Asians in this area of law was not to protect, but to exclude, to push to the edges of the state’s and the law’s protective umbrella not on the grounds of nativity, history, personal behavior or traditional ties to communities in which people lived and died. Rather the law used race and gender reified and redacted to suit other purposes and priorities.
The impact of shifting notions of race and gender varied over time. For example, the 1907 law treated all women equally in the form and manner that it denied or extended citizenship. With the passage of Cable, the creation of classes shaped by race, time and marital status confused the more straight-forward approach of the past. But what prompted this reconstruction? Were Cable’s complex classes the product of an unthinking process of ethnic and racial discrimination superimposed upon women’s legal status? How much of it was the need to encourage the arrival of Southern European immigrant women who were thought to be needed to replace the shortages of household servants and to be calming effects on their male countrymen already in America? To what extent was it a reaction or product of the granting of women the right to vote?
Alternatively, the retention or elimination of racial categories were linked to other historical forces. Using the Chinese as a scapegoat for elements wanting to restrict immigration, for example, helped to create a more broadly based white race that diverted attention away from domestic political rivalries themselves defined in racist fashion.
Historically citizenship in America rested on racial categories. By restricting naturalization to free whites, the Act of 1790 implicitly defined measures of worth in terms of race; subsequent events did not repudiate those categories, only reshaped them. In the first reification of these categories, the inclusion of blacks because of the Civil War, Charles Sumner suggested an amendment to the 1870 Naturalization Act eliminating white and therefore making the law race blind; it was soundly defeated. The defeat of the South not the end of racial categories was the driving force in altering the racial categories albeit incompletely between white and black. War, hot and cold, provided other incentives to modify and retain exclusionary policies. World War II raised the necessary specter of good and bad Asians; the continued exclusion of Chinese from citizenship was an uncomfortable embarrassment when they were allegedly gallant democratic allies. In a speech later published in the Bureau of Immigration and Naturalization Newsletter, Attorney-General Francis Biddle announced, “What has rendered peculiarly acute any mistreatment of racial minorities. . . is our reiterated insistence on democratic equality of opportunity, irrespective of race. The answer, of course, was to permit the naturalization of Chinese in 1943 and not the Japanese assigned to relocation camps or fighting in the armed forces. Other than men serving in the armed forces of the United States, Filipinos would not be allowed to be naturalized until 1946; and Japanese and Koreans, not until 1952, dates which have their own rationale in the crucibles of historic crises. In 1952, eligibility for naturalization shifted explicitly from race to an understanding of history, the principles and form of the American government and opposition to totalitarian government. In a sense then, as long as they were not red, Asians could be white.
While distinctions between the rights of citizens and non-citizens might appear to be ostensibly procedural in nature and race-blind, the substantive impact of those policies can still be prejudicial and racist. Dred Scot represented the most egregious example of the denial of recourse to the law because of his lack of citizenship and the case of Asian-American women caught in the circumstances described above another. Demonstrating the persistence of patterns of racial and gender discrimination, the lives of Asian women like Ah Quon, Dang and Yuen revealed the way in which the law reconstructed the reality of their lives to meet racial objectives and distributed legal burdens upon them. These patterns had an adverse impact upon those seeking to establish their nativity and nationality and illustrated the easy and capricious manner in which equal protection could be denied. Yuen and Dang did not have access to legal advice that might have altered the outcome of their pleas; both remained subject to the whims of administrative and legal process, and both were denied citizenship in the land of their birth.
The stories of Ah Quon, Lum, and Yuen are small stories that provide intriguing windows not only into the world of Asian immigrants and into American pluralism but into the significant forces and events that marked the nation’s history in the twentieth century. Embedded in these stories of citizenship is the history of America. The rapid growth of legislation prompted by Progressivism and New Deal, the resulting rationalization and codification, the rise of government administrative agencies and bureaucracies, the impact of imperialism, war and peace in an interdependent world, and altered concepts of race and gender can be seen through the life of women like Ah Quon who in their own small way sought to establish American dreams on the Gold Mountain.
Rose Quon Young Chu died on 6 November 1973 in Honolulu. The service was conducted by her pastor, an ordained Congregational minister who presided over the church in which Fook Ting had purchased a pew when the present sanctuary was constructed in 1929. At her funeral were her son David, a retired Honolulu police detective with over thirty years of service, and daughter Rose Ano, a clerk at Hickam Air Force Base whose office had been fired upon on 7 December 1941 and whose husband, a former master sergeant, had served in Western Europe with George Patton. Buried in a cemetery adjoining that of the Hawai’ian monarchs, she is presently survived by two grandsons, a granddaughter and four great-grandsons, of whom one is a member of the Colonial Society of Massachusetts, one, born in Canada when his father, a former American Air Force officer, was on a NATO assignment, and one, born literally in the shadows of the Museum of the Confederacy in Richmond, Virginia.
 Nathaniel Hawthorne, The Scarlett Letter in The Complete Novels and Selected Tales of Nathaniel Hawthorne, ed. by Norman Holmes Pearson (New York: Random House Modern Library ed., 1937), 85, 101.
 Both documents are in the possession of the author. Records of naturalization transactions for the United States District Courts of San Francisco, Sacramento, and Honolulu to 1961 are kept at the National Archives—Pacific Region, San Bruno, California.
 Yong Hee, Petition for Certificate of Live Birth, 14 March 1914. Marriage Certificate, 7 December 1912. Both documents are in the possession of the author.
 See Art. 17, §1 Constitution of the Republic of Hawai’i: “All persons born or naturalized in the Hawai’ian Islands and subject to the Jurisdiction of the Republic are citizens thereof.” quoted in Fundamental Laws of Hawaii, ed. Lorrin A. Thurston (Honolulu: Hawai’ian Gazette, 1904). Edward Lydon, The Anti-Chinese Movement in the Hawai’ian Kingdom, 1852–1886 (San Francisco, 1975), 42 and Gavan Daws, Shoal of Time: A History of the Hawai’ian Islands (New York: Macmillan, 1968), 252.
 31 Stat. 11. See the summary of the law governing Chu’s status on a similar set of facts in United States v. Dang Mew Wan Lum, 88 F (2d) 89 (1937). Chu’s status was not unusual. See the personal history of Agnes Yuen Sun Ki Yim (1894–1964) as described in her application for a certificate of identity that would allow her to re-enter the United States after a trip to China in 1923. A copy of the application may be found in Jack Kwan Yuen, “The Yuen Family” (unpub. ms., 1991), n.p.
 The obvious example of this, of course, is the Chinese Exclusion Act (1882) and a number of judicial decisions that barred Asians from naturalization. During the debates over the Naturalization Act of 1870, Charles Sumner offered an amendment that would have removed any reference to color. Voted down, the act only permitted the naturalization of whites and those of African descent. Zhang Qingson, “Dragon in the Land of the Eagle: The Exclusion of Chinese from U.S. Citizenship, 1848–1943” (Ph.D. diss., Univ. of Virginia, 1994), 98–100, and 148–47. 16 Stat. 255. For a definition of a national as opposed to a state-based citizenship, Crandall v. Nevada 73 U.S. 35, 44, 49 (1867).
 The prohibition of Chinese naturalization was overkill. The Naturalization Act of 1870 limited it to “free whites” and “aliens of African nativity and . . .persons of African descent.” 16 Stat. 256. Chinese Exclusion is 22Stat.89. For a summary of the relevant legislation, see Ronald Takaki, Strangers from a Different Shore: A History of Asian-Americans (Boston: Little Brown, 1989), 111–12, 373–78.
 Glick, Sojouners and Settlers, 128, 356–57. Daws, Shoal of Time, 211–12, 285, 304. The 1890 census lists 21,741 foreign-born of a total population of 25,767.
 Abstract of the Twelfth Census (Washington, DC: Govt. Printing Office, 1904), 41, 59.
 Ironically, of course, one of Hawai’i’s first senators was Hiram Fong, a Republican who would have sat on the same side of the aisle as Hoar and Lodge and who was a member of the Senate that confirmed both appointments of Lodge’s son as ambassador to South Vietnam. Fong’s family came from a village near that of Fook Ting, and he always addressed Ah Quon with the Chinese honorific “auntie.” Congressional Record, June 11, 1898, 5790–791. Merze Tate, Hawaiian Reciprocity or Annexation (East Lansing, 1968) 251–54.
 31 Stat. 161.
 The authority for this is found in Crandall v. Nevada. Nevada had sought to impose a rail and stage tax upon departing residents and persons passing through the state to other destinations. Justice Miller rested the majority opinion overturning the tax upon the commerce clause. Arguably, Crandall could be construed to be a limitation upon state, not federal action. If rooted purely in the commerce clause, Congress could act as it had done in the Organic Act. Miller, however, also grounded the opinion in a more fundamental right imbedded in both the First Amendment and in a reciprocal, contractual relationship between citizen and government. “If the government has these rights on her own account, the citizen has correlative rights.” A separate concurrence, written by Justice Clifford and endorsed by Chief Justice Taney, broadened the grounds for overturning the tax in precisely this fashion. Clifford expressed his strong doubts that even Congress had the power to levy this kind of tax. 73 U.S. 35, 44, 49 (1867).
 Petition for Certificate of Live Birth, 14 March 1914.
 The costs of proving one’s rights could, of course, be so prohibitive as to deny effectively their existence. See District Court Judge J. Frank McLaughlin’s 1943 advice to Shee Mui Chong Yuen. McLaughlin ordered the revocation of the Bureau of Immigration and Naturalization Service grant of a certificate of naturalization but urged Yuen, who had no lawyer present, to pursue an appeal because “this decision was out of harmony with the views of others and other courts.” In re Shee Mui Chong Yuen’s Repatriation,73 Fed. Supp 14 (1944).
 32 Stat. 176. The Hawai’ian sugar planters, who had begun to shift to Japanese labor which was not under the restrictions of the Chinese Exclusion Acts, did not oppose the restrictions. Many native Hawai’ians had already begun to oppose Chinese immigration as early as the 1880’s, and, as a result, Japanese population in Hawai’i leaped from 116 in 1884 to 12,610 in 1890 and 61,111 in 1900. Glick, Sojourners, 356–57.
 The date given is when the Organic Act, the legislation that established the territorial government and assimilates Hawai’ian institutions and law into the rest of the country. Technically sovereignty was transferred from the Republic of Hawai’i to the United States on 12 August 1898 by a joint resolution of Congress. In his petition for permanent residence under §102, Fook Ting claimed to have been in Hawai’i before 14 June 1894. This may have been a convention to satisfy legal requirements. In her petition for citizenship, Ah Quon claimed that Fook Ting had arrived in Honolulu on 15 September 1894. Petition for Naturalization, no 3963. 27 August 1940, Naturalization Records, National Archives—Sierra Pacific Region.
 Poi is the basic staple of native Hawai’ians and produced by cooking and mashing usually taro roots. Marriage Certificate, 7 December 1912, Lease, 31 August 1917, Possession of the author.
 Despite the fact that the bulk of Hawai’i’s Chinese community were from Guandong (Canton) and Ah Quon was Kejiaren (Hakka), a significant but smaller group of the Hawai’ian Chinese community, Chu was Sze Yup (Taishan), technically Guandongren (Cantonese) but a separate linguistic dialect.
 Honolulu City Directory, 1919.
 34 Stat. 1229.
 43 Stat. 1021.
 In re Ah Yup, 1 F Cas. 223 (C.C., Cal, 1878) at 223–24. 42 Stat. 1022, §§6–7
 Ex Parte (Ng) Fung Sing, 6 F 2d. 679 (1925). Sing’s situation also raises another interesting question. The National Origins Act provided a quota of 100 immigrants from China; if Chinese were barred from entry, who was eligible under the quota? Note that under In re Look Tin Sing, 21 F. 905 (1884) the child of a Chinese merchant born in the United States could not be barred from re-entry. As a citizen, he would not have come under the quotas: “the law could not intend that he should ever look to the government of a foreign country for permission to return to the United States and no citizen can be excluded from this country except in punishment for a crime.”
 See for example the case of Agnes Yuen Sun Ki Yim. According to her son, Charles Yim, she and his father were married in a Chinese temple and never reported the event to legal authorities. Interview, July 1991.
 46 Stat. 1512.
 46 Stat. 1512
 47 Stat. 571.
 Congressional Record, 2 May 1932.
 Houston’s mother was Caroline Poor Kahikiola Brickwood; his wife, Pinao Brickwood. Biographical Directory of the American Congress (Washington, DC: Government Printing Office, 1961),1080.
Not considered in this analysis is the status of Japanese-American women. Although relevant to the discussion, the timing of their immigration and the rapid increase of their numbers (jumping from 24,407 to 61,111 between1890 and 1900) makes estimates of married and divorced former citizens more problematic and compels a more detailed examination of data not available in published census reports. Suffice to say, the legal status of American citizens of Japanese ancestry would not differ from those of Chinese. Glick, Sojourners, 356-357. Fifteenth Census of the United States Taken in the Year 1920: Outlying Possessions (Washington, DC: Government Printing Office, 1932), 49, 61–62.
 Note too that in the case of Chinese women over 21 in 1920, 52.4% were native born and “naturalized foreign born [sic]”. Fifteenth Census, 61-62. Glick, Sojourners, 162. Fourteenth Census of the United States Taken in the Year 1920, vol. 3 Population (Washington, D.C.: Government Printing Office, 1922), 1175.
 3 F 2d. 44 (1925). United States Department of Labor, Bureau of Immigration and Naturalization, Enforcement of Immigration Laws in Relation to Insular Possessions and Territories, lecture by A.R. Archibald, January 14, 1935, 8-9.
 Thind may be found at 261 U.S. 204 (1923); Ali at 7 F 2nd, 732 (1925).
 49 Stat. 1917.
 United States v. Dang Mew Wan Lum, 88 F(2d) 89 (1937). How Dang received the initial certificate is not clear. While there has been no concerted study of the phenomenon, the fact of the matter is that concurrent jurisdiction for naturalization still technically exists. That is to say, state courts of record have the power to naturalize citizens; they must do so, however, consistent with federal regulations.
 Cong. Record, 6 July 1939.
 The only benefit the women received was to be exempt from providing a certificate of arrival if they had been continuously resident in the United States during the course of their marriages. 42 Stat. 1022.
 “Hereafter a woman, being a native-born citizen, who has or is believed to have lost her United States Citizenship solely by reason of her marriage prior to 22 September 1922, to an alien, and whose marital status has or shall have terminated shall be deemed to be a citizen of the United States to the same extent as though her marriage to said alien had taken place on or after 22 September 1922 [italics added].” 49 Stat. 1917.
 Her brother Fred A. Young provided the other deposition. The date used on the petition to establish evidence of continued residence was Yee Moi’s birthday, 15 March 1916. Petition for Naturalization, 27 August 1940.
 49 Stat. 1917.
 Certificate of Naturalization, no 4887931.
 8 Nov. 1943, Record Group 85
 Cong. Record, 11 Sept. 1940, 11944–1950, 4 Oct. 1940, 13249.
 The Act provided for the rights of naturalization to be made available to “white persons, persons of African nativity or descent and descendants of races indigenous to the Western Hemisphere” and “native-born Filipinos having the honorable service in the United States Army, Navy, Marine Corps, or Coast Guard.” 54 Stat. 1140. The exception made for Filipinos was obviously an incentive given to them at the moment in which Douglas MacArthur was building a Filipino Constabulary in anticipation of problems with Japan.
 In response to the INS claims that similarly situated women were already citizens and ought not to have to submit petitions for naturalization, McLaughlin held that the Nationality Act repealed the law and swept away any rights of suspended or undocumented citizenship since there could be but “one class of citizens, namely full-fledged citizens. In re Shee Mui Chong Yuen’s Repatriation, 73 F Supp. 12, esp. 14 (1944).
 57 Stat., 601. See also the testimony of people like Pearl Buck in United States Congress, Hearings before the Committee on Immigration and Naturalization: House of Representatives 78th Congress on HR 1882 and HR 2309 Bill to Repeal the Chinese Exclusion Acts and to Put the Chinese on a Quota Basis and to Permit Their Naturalization: May 19, 20, 26 . . . (Washington, Government Printing Office, 1943).
 He died on 15 September 1940.
 Honolulu Advertiser, 1 September 1940. One of the individuals being naturalized was a neighbor and the mother of a childhood friend of Ah Quon’s future daughter-in-law.
 In re Yuen, 15
 Bina Kolola, “Immigration Laws and The Immigrant Woman: 1885–1924,” Georgetown Immigration Law Journal, 11 (1997):555–56
 Jonathan M. Chu, “George Frisbie Hoar and Chinese Exclusion: The Political Construction of Race,” Faces of Community: Immigrant Boston, 1860–2000, ed. By Conrad Edick Wright and Reed Ueda (Boston: Massachusetts Historical Society, 2003). 18–19. Matthew Jacobson, Whiteness of a Different Color: European Immigrants and the Alchemy of Race (Cambridge, MA: Harvard University Press, 1998), 1–12. See also, Alexander Gyorny, Closing the Gate: Race, Politics, and the Chinese Exclusion Act,(Chapel Hill, NC: University of North Carolina Press 1998), 6–16, Stuart C. Miller, The Unwelcome Immigrant: The American Image of the Chinese, 1785–1882 (Berkeley and Los Angeles: University of California Press, 1969), esp. 191, 204, and Alexander Saxton, The Indispensable Enemy: Labor and the Anti-Chinese Movement in California (Berkeley and Los Angeles: University of California Press, 1971), esp. 133–34, and 230.
 Zhang Qingson, “Dragon in the Land of the Eagle: The Exclusion of Chinese from U.S. Citizenship, 1848-1943” (PhD diss, University of Virginia, 1994), 98–100, 148–47.
 Biddle is quoted in Charles Gordon, “The Racial Barrier to American Citizenship,” University of Pennsylvania Law Review (1945): 253. Stanford M. Lyman noted that a limited number of Chinese were naturalized prior to the Exclusion Act. “The Race Question and Liberalism: Casuistries in American Constitutional Law,” International Journal of Politics, Culture and Society 5 (1991): 234.
 57 Stat. 600, 60 Stat. 416, 66 Stat.239.
 Diane Mei Lin Mark, Seasons of Light: The History of Chinese Christian Churches in Hawai’i (Honolulu, 1989), 58.