Wednesday, November 13, 2013

The Japanese Immigrant Case (Yamataya v. Fisher) case brief

The Japanese Immigrant Case (Yamataya v. Fisher) case brief summary
189 U.S. 86 (1903)


CASE SYNOPSIS
Appellant, a subject of Japan, was ordered deported by the Immigrant Inspector on the grounds that she was a person likely to become a public charge under the Act of March 3, 1891, 26 Stat. 1084. A writ of habeas corpus was issued, but upon a return by the Inspector, the United States District Court for the District of Washington dismissed the writ and remanded appellant for deportation. The United States Supreme Court granted review.

CASE FACTS
Appellant, a subject of Japan, was ordered deported by the Immigrant Inspector on the grounds that she was a person likely to become a public charge under the Act of March 3, 1891, 26 Stat. 1084. A writ of habeas corpus was issued, but upon a return by the Inspector, the lower court dismissed the writ and remanded appellant for deportation.


DISCUSSION

  • The United States Supreme Court granted review and affirmed. 
  • It held that Congress had authority to define through legislation the terms and conditions under which aliens would be admitted and that the treaty with Japan of 1894, Nov. 23, 1894, U.S.-Japan, Article I - II, 29 Stat. 848, 849, did not proscribe that right. 
  • It further held that the decisions of administrative or executive officers acting under their delegated powers constituted due process of law and were not subject to judicial review; since it appeared that appellant had been afforded an opportunity to be heard and since she did not take an appeal to the Secretary of the Treasury from the decision of the Inspector, that decision was final and conclusive.

CONCLUSION

The court affirmed, holding that Congress had the authority to define the terms under which aliens could be admitted; that decisions of the administrative and executive officers under their delegated authority were not subject to judicial review; and that since appellant had been afforded an opportunity to be heard and since she did not appeal to the Secretary of the Treasury from the inspector's decision, that decision was final and conclusive.

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