United States v. Lee Yen Tai

Background

Lee Gin Moy (also called Lee Yen Tai) was arrested after a federal commissioner found he was a Chinese laborer who entered the United States without the required certificate and ordered his deportation. While the marshal prepared to remove him, he sought a federal habeas corpus release, claiming he was a merchant with a $1,000 interest in a firm and not a laborer. The District Court released him on bail and the United States appealed. The certified legal question to this Court was whether a prior federal statute (section twelve of the 1882 Chinese exclusion law, as amended) was abrogated—canceled—by a later 1894 treaty with China.

Reasoning

The Court examined the treaty and the statute and explained that treaties can override statutes only when their words clearly show that result. The opinion reviewed prior cases and said that courts should try to make a statute and a treaty work together if possible. Here the Court found no clear conflict. Section twelve, as amended and continued in force, can function alongside the 1894 treaty and in fact advances the treaty’s stated goals of preventing unlawful entry. The Court therefore answered the certified question negatively: the statute was not abrogated and remains enforceable.

Real world impact

Practically, the decision means the federal procedures in the 1882–1884 law remain available to identify and remove Chinese laborers who lack the required certificate. It affirms the continuing role of commissioners, marshals, and designated peace officers in carrying out removals under that statute. An order stating this answer was sent back to the Court of Appeals.