Takao Ozawa v. United States, 260 U.S. 178 (1922), was a US legal proceeding. The United States Supreme Court found Takao Ozawa, a Japanese American who was born in Japan but had lived in the United States for 20 years, ineligible for naturalization. In 1914, Ozawa filed for United States citizenship under the Naturalization Act of 1906. This act allowed only "free white persons" and "persons of African nativity or persons of African descent" to naturalize. Ozawa claimed that Japanese people should be properly classified as "free white persons".
Political context
The U.S. Supreme Court had originally been hesitant to take on the case presented by Takao Ozawa. One reason was the changing policy resulting from the unclear state of laws during wartime in the United States during World War I.
Japan had sided with the Allied Powers on August 23, 1914, hoping to expand its influence in China as well as the Pacific using the Anglo-Japanese Treaty. This was an alliance between the United Kingdom and Japan (January 30, 1902 - August 17, 1923). Because Japan was the first non-white nation to attend a peace conference, they brought with them a proposal to address racial inequality and white supremacy to the Paris Peace conference on January 18, 1919. This was a conference meant to reestablish peace after the events of World War I.
Japan made three demands in their proposal. The first two were territory related and involved the potential retrocession of territories held in Shandong and the Central Pacific. Japan had made secret treaties in order to secure these territories and had highly contested the idea brought up in the conference to cede them. The third peace term demand was the racial equity proposal in which Japan demanded equity to their Western allies.
The United States had been more tolerant when it came to the proposal at first, as opposed to the British, asking Japan to draft two proposals: "one which they desired, and another which they would be willing to accept in lieu of the one they prefer". Opposition to the proposal in Britain and the United States was heavily influenced by racial tensions, Japan being the only non-white great power among the allies causing distrust and hesitation toward their proposal. In 1894, he moved to San Francisco, California, where he attended school. After he graduated from Berkeley High School, Ozawa attended the University of California. In 1906, after graduating, he moved to Honolulu, Hawaii. After settling down in Honolulu, Ozawa learned English fluently, practiced Christianity, and obtained a job at an American company. He reported his background as purposeful attempts toward assimilation, writing: