Terrace v. Thompson
Headline: Washington's Anti-Alien Land Law upheld, the Court rejects constitutional and treaty challenges, allowing the state to bar many non-declarant and ineligible aliens from owning or leasing agricultural land.
Holding: The Court upheld Washington’s law barring aliens who have not declared intent to naturalize from owning or leasing defined agricultural land, rejecting Fourteenth Amendment and treaty challenges and affirming the lower court’s dismissal.
- Allows Washington to bar many non-declarant and ineligible aliens from owning agricultural land.
- Leaves landowners unable to lease to such aliens without risking forfeiture or criminal penalties.
Summary
Background
A group of Washington residents who own a vegetable farm asked a federal court to block the State Attorney General from enforcing Washington’s 1921 Anti-Alien Land Law. The owners wanted to lease the land for five years to a Japanese-born man who is a national of Japan and a resident, but the Attorney General threatened criminal penalties and forfeiture under the statute if they did so.
Reasoning
The Court first found equity jurisdiction proper because the threatened enforcement would prevent the owners and the tenant from making the lease and would cause continuing injury. On the merits, the Court held the State may withhold ownership or lease rights from aliens who have not, in good faith, declared an intention to naturalize and from those ineligible for citizenship. The Court rejected the claim that the law violated the Fourteenth Amendment’s due process or equal protection clauses, saying the State’s classification rests on eligibility and intent to naturalize and is not arbitrary. The Court also found the 1906 U.S.–Japan treaty did not grant a right to own or lease agricultural land.
Real world impact
The ruling affirms that Washington may prohibit many non-declarant and ineligible aliens from holding title or the defined interests in agricultural land, and it leaves owners and prospective tenants unable to contract without risking the law’s penalties. The decision upholds state control over agricultural land ownership despite treaty and constitutional challenges, and it affirms the District Court’s dismissal of the complaint.
Dissents or concurrances
Two Justices would have dismissed the case for lack of a justiciable question, saying the Court should not have decided the merits.
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