Porterfield v. Webb, Attorney General of California

Background

A California landowner, a U.S. citizen, wanted to lease his 80-acre vegetable farm to a Japanese-born farmer who is a subject of Japan. State officials threatened to enforce a 1920 voter-approved California Alien Land Law that limits land rights for certain noncitizens and imposes penalties, including forfeiture and imprisonment. The landowner and the prospective tenant sued to stop enforcement and asked for a temporary injunction; three judges denied that request under the Judicial Code.

Reasoning

The central question was whether California could treat noncitizens who are not eligible for U.S. citizenship differently on land ownership and leasing. The law’s key sections allow aliens who are eligible for citizenship to hold land like citizens, but restrict other aliens to whatever rights a treaty allows. The Court relied on its earlier decision in Terrace v. Thompson and concluded California’s distinction was not arbitrary. The Court noted the United States–Japan treaty did not give Japanese subjects the right to acquire or lease agricultural land. The Court therefore affirmed the lower court’s order refusing to block enforcement of the state law.

Real world impact

The ruling lets California continue to prevent certain noncitizens from acquiring or leasing farmland and permits the state to enforce penalties against violations. It leaves landowners who might lease to ineligible noncitizens unable to test the law by entering into leases without risking forfeiture or criminal penalties. The decision treats state classification of noncitizen groups as within the state’s broad discretion.

Dissents or concurrances

Two Justices said no justiciable question existed and would have dismissed the case instead of deciding the merits.