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Political science research paper topics

Political science research paper topics

Case Analysis

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

Introduction

The paper is a case analysis of the case of Oyama v. California, 332 U.S. 633 (1948), including its sociohistorical context, the facts, ruling, the rationale of the court’s decision, and the opinions of dissenting judges. Also discussed in the importance of the case and how its debates continue to feature in today’s society.

The Sociohistorical Context of the Case

Before the decision in the Oyama case, various states came up with alien land laws that prevented non-citizens who were not eligible for citizenship to lease or own land. The laws mostly targeted Japanese. The validity of the laws were upheld by the courts because traditionally, the states held the authority of regulating the property rights of aliens (Villazon, 984). Ultimately, equality principles in land ownership prevailed over the laws in Oyama v. California 332 U.S. 633 (1948), where the court struck down the application of California‘s Alien Land Law to American citizens. The statute limited the rights of American citizens in property ownership where property was bought on their behalf by non-citizen parents (Villazon, 984). The legal issues challenged by the case were equal protection and property rights in America. The case paved the way towards equality in property ownership, which was enshrined in Shelley v. Kraemer 334 U.S. 1 (1948). In the Shelly case, the court held that enforcement of private racial covenants by the judiciary violated the 14th amendment equal protection clause. Politically, the case was instrumental in turning the tide against public discrimination of interned Japanese families. The vigorous enforcement of the laws in California revealed the state’s intention to remove the Japanese community from California (Villazon, 985). The case provided security measures against the efforts of excluding the Japanese population. It also stalled the continued state discrimination against Japanese landholding (Villazon, 985-986). Therefore, the Oyama decision protected the Japanese Americans’ right to own property.

Facts of the Case

In this case, the petitioners, Fred Oyama, a minor, and Kajiro Oyama, his father, challenged the constitutionality of California’s alien land law. The law was applied to escheat two parcels of agricultural land owned by the Oyama’s. The petitioners argued that the statute denied the minor equal protection of the laws and privileges as a citizen of the US. Secondly, it denied Kajiro Oyama equal protection of laws, and thirdly, it contravened the laws of due process because the property was acquired by the state after the applicable limitation period had expired (332 U.S. 633, 636). In the state’s trial court, the lower court escheated the agricultural land recorded in the minor’s name, who was an American citizen to the state, because his father who was an alien not eligible for naturalization, paid for them. The state trial court granted certiorari (332 U. S. 640-647).

The Ruling

The Supreme Court determined that the trial court’s intention was justified by the evidence. California had the power to exclude ineligible non-citizens from having an interest in agricultural land constitutionally. The minor was not deprived of any guarantees in the constitution because the properties passed directly to the state (332 U.S. 633, 640). The alien land law denied the citizen son equal protection and privilege as an American citizen, violating the fourteenth amendment. The court reversed the trial court’s certiorari and allowed the Oyama’s to keep their land (332 U. S 633, 641).

The rationale for the decision was that the application of the alien land law discriminated against Fred, the son, in three respects. The first was that the statutory premafacie presumption was that the conveyances were not gifts because they were held for the father’s benefit. California applied the rule that a presumption of a gift was intended where a conveyance was by a parent to a child (332 U. S. 641-642, 644-645). Secondly, where a father did not qualify for citizenship, the facts proving a son’s ownership made the ownership suspicious. Where the father was an eligible non-citizen, the facts would prove the intention of a completed gift (332 U. S. 634, 642). The underlying reason for discrimination that caused the citizen son to lose the land completely was that the father was Japanese (332 U. S. 644-645). Race-based discrimination among aliens was deemed unconstitutional.

The dissenting opinions as provided by justices reed and burton averred that the state provided premafacie evidence that the conveyance made by the Oyama’s was intended to escheat the state. The purpose of the Californian alien land law could not be realized unless the law’s prohibitions were penalized. Therefore, any law that denied unqualified non-citizens to own property that failed to prevent owning and attempting to enjoy property rights would be defective (332 U.S. 633, 677). Concerning the discrimination of the minor, as a US citizen, the justices averred that the discrimination was relevant because it challenged the presumption that the burden of proof put on the son denied him equal protection, and therefore, was unconstitutional. The rationale was that the classifications were reasonable, where it was assumed that the state of California could prohibit land ownership by a Japanese, directly and indirectly (332 U.S. 633, 684). Justice Jackson averred that he could not see the logic of court’s logic in setting the judgment aside the law on which the decision was based would be invalidate (the California Alien Land Laws). The justice maintained that the escheat judgment was found to be harsh because it was implementing a legislative policy that had not had its validity questioned by the court (332 U.S. 633, 685).

Importance of the Case

The Oyama case provides an intersection between citizenship, property, and race. It demonstrates how citizenship was applied by the alien land laws to deny individuals, especially Japanese, property ownership rights (Villazon, 988).  The Oyama legacy is relevant in today’s society because the court failed to deal with the father’s discrimination claim. Therefore, the power of states to regulate property rights of aliens remained untouched. The power enables local governments to claim that they have the authority to employ police powers in passing restrictions on local housing that deny non-citizens property-renting abilities (Villazon, 988). Looking at the law through the case, the current application of local property regulations can be seen as present times alien land laws (Villazon, 988). The loophole in the case has given local governments leeway for bringing in the very laws that the case sought to eliminate.

Conclusion

The Oyama case was significant when it was decided and even today because it eliminated discrimination of ineligible non-citizens to owning property. However, it left a loophole for local governments to apply their police power to formulate laws restricting non-citizens from renting property.

Works Cited

Villazor, Rose Cuison. Rediscovering Oyama v. California: At the Intersection of Property, Race, and Citizenship. Washington University Law Review. 2010. 3 October 2019 <https://openscholarship.wustl.edu/cgi/viewcontent.cgi?referer=&httpsredir=1&article=1101&context=law_lawreview>.

Case Laws

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

Shelley v. Kraemer 334 U.S. 1 (1948).

Terrace v. Thompson, 263 U.S. 197, 222 (1923)

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