"Priceless Possession" of Citizenship: Race, Nation and Naturalization in American Law, 1880-1930
Duquesne Law Review Volume 43 Number 3 Article 4 2005 The "Priceless Possession" of Citizenship: Race, Nation and Naturalization in American Law, 1880-1930 J. Allen Douglas Follow this and additional works at: https://dsc.duq.edu/dlr Part of the Law Commons Recommended Citation J. A. Douglas, The "Priceless Possession" of Citizenship: Race, Nation and Naturalization in American Law, 1880-1930, 43 Duq. L. Rev. 369 (2005). Available at: https://dsc.duq.edu/dlr/vol43/iss3/4 This Article is brought to you for free and open access by Duquesne Scholarship Collection. It has been accepted for inclusion in Duquesne Law Review by an authorized editor of Duquesne Scholarship Collection. The "Priceless Possession" of Citizenship: Race, Nation and Naturalization in American Law, 1880- 1930 J. Allen Douglas' I. INTRODUCTION In 1921, as restrictive immigration policy in the United States quickened, the federal district court in Washington State consid- ered the plea of N. Nakatsuka to lease land for agricultural devel- opment in the face of the state's newly implemented "Anti-Alien Land Law."' Writing for the court, Judge Cushman noted that, as an alien resident, Nakatsuka could neither lease nor own land in the state, as that was a privilege limited to American citizens.' 1. Law Clerk to the Hon. Robert B. Krupansky, U.S. Court of Appeals, Sixth Circuit, JD Cornell Law School, M.A., Ph.D. American History, Rutgers University. For their con- tributions, ideas and advice on this article I thank Jim Livingston, Stan Katz, Jackson Lears, Joan Scott, David Lyons, and Caroline Goeser. For their support I also thank the Woodrow Wilson National Fellowship Foundation and the Center for the Critical Analysis of Contemporary Culture at Rutgers University.
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