Lee Lung v. Patterson
Headline: Court affirms dismissal, upholding customs officers’ refusal to admit alleged Chinese wife and daughter and leaving review to Treasury appeal process rather than federal courts, affecting detained noncitizens seeking entry.
Holding:
- Affirms executive control over immigration admission decisions denying Chinese family members.
- Limits federal courts from reexamining collectors’ admission decisions without statutory authorization.
- Leaves appeals to the Treasury Department as the available remedy.
Summary
Background
A Chinese merchant who lived for many years in Portland returned from a trip to China with a woman he said was his wife and a girl he said was his daughter. The local customs collector allowed the merchant to land but refused to admit the woman and child despite certificates from Hong Kong and U.S. consular visés. The women were detained aboard the ship and an appeal was taken to the Treasury Department. The merchant then asked a federal court to free them and to review the collector’s actions.
Reasoning
The central question was whether a federal court could review the collector’s decision denying admission of these Chinese persons. The Court relied on prior decisions holding that the collector has authority to decide such entry questions and that those decisions are conclusive, subject only to the internal appeal to the Treasury Department. The Court found the district court lacked power to reexamine the executive officers’ factual determinations and therefore affirmed dismissal of the petition.
Real world impact
The decision leaves challenges to landing denials for Chinese persons to the administrative appeal process at the Treasury rather than to federal courts. It confirms that collectors may judge certificates and evidence presented at ports, and that unsuccessful applicants must rely on the department’s review. The ruling therefore affects people detained at ports claiming family ties to exempt classes.
Dissents or concurrances
Two Justices (Brewer and Peckham) dissented, and one Justice (Gray) did not participate, as noted in the opinion.
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