Sei Fujii v. State of Cal. - 38 Cal. 2d 718, 242 P.2d 617 (1952)

Rule:

The California Alien Land Law is invalid as a violation of the Fourteenth Amendment.

Facts:

Plaintiff, an alien Japanese man who is ineligible to citizenship under our naturalization laws, appeals from a judgment declaring that certain land purchased by him in 1948 had escheated to the state. There is no treaty between this country and Japan which confers upon plaintiff the right to own land, and the sole question presented on this appeal is the validity of the California Alien Land Law.

Issue:

Is the California Alien Land Law valid?

Answer:

No.

Conclusion:

The court reversed the lower court's judgment. The court held first that the U.N. Charter did not provide relief for the alien resident because it was not a self-executing treaty so as to supersede inconsistent state legislation as provided in U.S. Const. art VI. However, the court determined that the Alien Land Law violated the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The court held that the statutory classification of aliens on the basis of eligibility to citizenship was suspect because it in fact classified on the basis of race or nationality. Applying a "most rigid scrutiny" standard of review, the court found that the legislation was not reasonably related to any legitimate governmental interest.