Oyama v. California, 332 U.S. 633 (1948)

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Oyama v. California

No. 44

Argued October 22, 1947
Decided January 19, 1948
332 U.S. 633

CERTIORARI TO THE SUPREME COURT OF CALIFORNIA

Syllabus

1. The California Alien Land Law, as applied in this case to effect an escheat to the State of certain agricultural lands recorded in the name of a minor American citizen because they had been paid for by his father, a Japanese alien ineligible for naturalization who was appointed the son’s guardian, held to have deprived the son of the equal protection of the laws and of his privileges as an American citizen, contrary to the Fourteenth Amendment and R.S. § 1978. Pp. 640-647.

2. The Alien Land Law, as applied in this case discriminated against the citizen son in the following respects:

(a) By a statutory prima facie presumption that conveyances financed by his father and recorded in the son’s name were not gifts to the son, but that the land was held for the benefit of the father, whereas, for most minors, California applies the rule that, where a parent pays for a conveyance to his child, it is presumed that a gift was intended. Pp. 641-642, 644-645.

(b) Because, under the laws of California as applied by its courts when the father is ineligible for citizenship, facts which would usually be considered indicia of the son’s ownership are used to make that ownership suspect, whereas, if the father were not an ineligible alien, the same facts would be evidence that a completed gift was intended. P. 642.

(c) By being required to counter evidence that his father was remiss in his duties as guardian, whereas no other California case has been called to this Court’s attention in which the penalty for a guardian’s derelictions has fallen on the ward. Pp. 642-644.

3. The sole basis for this discrimination, which resulted in a citizen’s losing the land irretrievably and without compensation, was the fact that his father was Japanese. Cockrill v. California, 268 U.S. 258 distinguished. Pp. 644-645.

4. Such discrimination against a citizen on the basis of his racial descent cannot be justified on the ground that it is necessary to prevent evasion of the State’s laws prohibiting the ownership of agricultural land by aliens who are ineligible for citizenship. Pp. 646-647.

29 Cal.2d 164, 173 P.2d 794, reversed.

The Supreme Court of California affirmed a decision of a state trial court declaring escheated to the State under the California Alien Land Law, 1 Ca.Gen.Laws, Act 261, as amended, certain agricultural lands recorded in the name of a minor American citizen, which lands had been paid for by his father, a Japanese citizen ineligible for naturalization. 29 Cal.2d 164, 173 P.2d 794. This Court granted certiorari. 330 U.S. 818. Reversed, p. 647.