Native Americans were not the only ethnic or racial group singled out in U.S. citizenship laws. Passed in 1882, The Chinese Exclusion Act severely limited immigration into the United States from China, disallowing all laborers and expanding a previous ban on Chinese women. There were challenges to this law, including United States v. Wong Kim Ark in 1898. Wong Kim Ark was born to Chinese parents in San Francisco. He left to visit family in China at age 21 and was denied re-entry to the United States because he was not a citizen under the Chinese Exclusion Act. The court ruled in favor of Wong Kim Ark, establishing the concept of jus soli, or the right of any child born on U.S. land to citizenship, regardless of the nationality of the parents. Variations of the Chinese Exclusion Act would remain in place until the Magnuson Act, passed in 1943. This allowed Chinese people within the country to apply for citizenship and opened immigration from China.

Document F

A Frank Leslie cartoon titled, “The Only One Barred Out.” Published in 1882.

Document G

An excerpt from the Supreme Court opinion from United States v. Wong Kim Ark, decided March 28, 1898.

“The facts of this case, as agreed by the parties, are as follows: Wong Kim Ark was born in 1873 in the city of San Francisco… His father and mother were persons of Chinese descent, and subjects of the Emperor of China; they were at the time of his birth… residents of the United States… Wong Kim Ark, ever since his birth, has had but one residence… in California, within the United States, and has there resided, claiming to be a citizen of the United States, and has never lost or changed that residence… he remained in the United States… until 1894, when he… departed for China on a temporary visit and with the intention of returning to the United States, and he did return… in August, 1895, and applied… for permission to land, and was denied such permission upon the sole ground that he was not a citizen of the United States…

The question presented by the record is whether a child born in the United States, of parents of Chinese descent… in the United States… becomes at the time of his birth a citizen of the United States by virtue of the first clause of the Fourteenth Amendment of the Constitution…

That all children born within… the United States of foreign parents… became citizens at the time of their birth does not appear to have been contested or doubted until more than fifty years after the adoption of the Constitution… He must reside within the State to make him a citizen of it, but it is only necessary that he should be born or naturalized in the United States to be a citizen of the Union.”