In 1888, Congress passed the Scott Act which revoked the right of Chinese laborers to re-enter the United States after visiting China. Chinese in the United States before the 1882 Chinese Exclusion Act was passed were able to return without impediment to the United States if they "obtained a certificate before their departure and could produce this document upon their return". The Chinese Exclusion Act of 1882 prohibited the immigration of Chinese laborers for a period of ten years and restricted all Chinese immigrants from obtaining naturalized citizenship, while at the same time allowing "merchants, teachers, students, travelers, and diplomats" to be exempt from these exclusions. This case marked a shift in the court in respect to habeas corpus petitions and altered the judicial landscape for citizens applying for admission into the United States as well as for those facing deportation. The Court determined that refusing entry at a port does not deny due process and held that findings by immigration officials are conclusive and not subject to judicial review unless there is evidence of bias or negligence. The case held that "a citizen of Chinese parentage seeking admission to the United States" could be excluded by the administrative immigration authorities, even when being denied a hearing before a judicial body on the question whether they were indeed a citizen. ![]() 253 (1905), is a United States Supreme Court case in which the Supreme Court conceded its right to judicial review over immigration matters. Holmes, joined by Fuller, Harlan, Brown, White, McKenna ![]() The petition for habeas corpus should have been denied, refusing entry at a port does not deny due process and the findings of the immigration officials were conclusive and not subject to judicial review.Ĭhief Justice Melville Fuller Associate Justices John M. Federal District Court ruled that Ju Toy was a person native to the United States and ordered his release.
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