"United States v. Bhagat Singh Thind" (1923) is a notable Supreme Court case that significantly impacted U.S. immigration law, particularly concerning the racial eligibility of immigrants for naturalized citizenship.
- Bhagat Singh Thind: The petitioner, Bhagat Singh Thind, was an Indian Sikh man who had legally emigrated to the United States. He had served in the U.S. Army and completed his university education in America.
- Application for Citizenship: Thind applied for U.S. citizenship, which at the time was restricted to "free white persons" and "persons of African nativity or descent" under the naturalization laws.
The Legal Issue:
- Eligibility for Naturalization: The key legal question was whether Thind, being an Indian and a high-caste Hindu of Aryan descent, could be classified as a "white person" and thus eligible for naturalization.
- Unanimous Ruling: The Supreme Court, in a unanimous decision, ruled against Thind.
- Opinion by Justice Sutherland: Justice George Sutherland, who also wrote the opinion in Ozawa v. United States, delivered the Court's opinion.
Key Legal Points:
- Definition of 'White Person': The Court held that the term "white person" in the naturalization laws did not include people of Indian descent.
- Common Understanding of Race: The decision emphasized the "common understanding" of the term "white person" as understood by the "average man," which the Court concluded did not correspond to the anthropological and scientific classification of an Aryan.
- Rejection of Aryan Argument: Although Thind argued that as an Aryan, he belonged to the same racial category as Caucasians, the Court rejected this argument.
Impact and Legacy:
- Exclusion of South Asians from Citizenship: This ruling effectively barred people of South Asian descent from becoming naturalized American citizens.
- Racial Criteria in Immigration Law: The decision, alongside Ozawa v. United States, underscored the racial criteria that dominated American immigration and naturalization law in the early 20th century.
- Revocation of Citizenship: Following this decision, some Indians who had previously naturalized had their citizenship revoked.
- Change in Legislation: The racial restrictions in U.S. citizenship laws were eventually dismantled by the Immigration and Nationality Act of 1952.
"United States v. Bhagat Singh Thind" is a significant case in the history of U.S. immigration law, reflecting the era's racial attitudes and its impact on immigration policy, particularly for immigrants from Asia.