In re Saito
In re Saito was a naturalization case that took place in Massachusetts in 1894. Shebalto Saito, a Japanese immigrant, filed paperwork to become a citizen of the United States. On June 27, 1894, Judge LeBaron B. Colt of the Circuit Court of the District of Massachusetts in Boston, ruled on Mr. Saito's petition. The key question in this case was whether Mr. Saito was eligible for citizenship as a Japanese immigrant. The Naturalization Act of 1870 had been expanded to include those of African descent, to reflect the 14th Amendment, which redefined who could be citizens of the United States. In this era soon after the 14th Amendment was passed, many immigrants to the United States applied for citizenship to challenge previous restrictions that had only allowed Caucasian people to naturalize. Judge Colt concluded that the Japanese belonged to the “Mongolian” race, and denied Mr. Saito's petition. The case became a prerequisite case for future cases determining the race and citizenship eligibility of Japanese people in the United States.
History
Shebalto Saito's Immigration
Shebalto Saito was 29 years old when he applied for naturalization in 1894. He had emigrated from Japan about 15 years earlier in 1879 and had lived in Boston for most of that time. Saito was married and had several children. Most Japanese immigrants settled in the United States in agricultural jobs, building railroads, working in saw mills and factories, usually in the Western states, especially Hawaii. The wages in the United States were much higher than in Japan, and the lure of better wages brought many Japanese men to work there. The hope was to save up enough money to establish themselves in the United States or to return home with enough money to become a farmer or a merchant.Though the largest numbers of Japanese immigrants were located in the West Coast, there were small Japanese immigrant communities in New England, where In re Saito took place. Connecticut and Massachusetts had the largest Japanese communities in the region. The first Japanese immigrant arrived in Boston around 1890. Many Japanese immigrants worked in naval jobs or in supporting industries - like restaurants and housing. Universities in Boston also attracted some Japanese students to the region.
The court case, In re Saito, covers his application for citizenship which was denied in 1894. An immigrant had to be living in the United States for five years and must have resided in the state they were filing in for at least one year to meet the application requirements. In the late nineteenth century, the citizenship process took at least five years. First, an immigrant had to file a Declaration of Intent. Two years later, they could petition for naturalization.
Racial Hierarchies
By the late nineteenth century in the United States of America, racial hierarchies had developed as different ethnic groups interacted with each other. For example, the terms “Caucasian,” “Negro,” and “Indian,” were used to describe what was thought of as the three races of America. In general, white Americans believed they were the superior race and should rule over other races, claiming that other races were incapable of good democracy.As white Americans began to have more encounters with Asian countries through trade and immigration, new racial categories developed. People from Asia were often referred to as “Mongolian” or “yellow” and classified as inferior to white people but superior to Black people. However, racial categorization was not set-in-stone. Rather, the perceptions of different races were created and contested through various legal and social processes. During this time, the racial treatment of Japanese immigrants in the United States was a gray area. Some considered Japanese to be the same as, or similar to, the Caucasian race. Others grouped them with the Chinese, or “yellow” race. Eventually, Japanese immigrants applied for citizenship and their racial status was contested in courts. The cases that determined racial categories were significant factors in the formation of racial hierarchies in the United States. Those courts usually denied citizenship based on perceptions of race, solidifying Japanese immigrants' status as non-white. In re Saito was a pivotal case in the racialization of Japanese immigrants.
In the nineteenth century, Japanese immigrants to the United States were treated as similar to the Chinese, but slightly superior. In the beginning stages of Japanese immigration to America, white Americans thought of them more positively than Chinese immigrants. Japan was viewed as a more civilized nation than China, because of its government, culture, and willingness to adopt some Western practices. In the latter nineteenth century as the Chinese state experienced failure and Chinese immigration to the United States increased, Americans’ perceptions of the Chinese grew increasingly negative. Then, as the Japanese gained more international power and political influence, they were racially described as threatening and inferior. Some race historians describe this process as “turning from white to yellow.” More and more, Japanese immigrants were categorized as “Mongolian” and the distinction between Chinese and Japanese began to disappear in the minds of many white Americans.
Precedent Cases
In re Saito was one of twelve precedent cases that dealt with application for citizenship by non-European persons from 1878 to 1909. The applications came from Chinese, Hawaiian, Burmese, Japanese, Mexican, Asian Indian, and mixed race immigrants. Eleven of the twelve applications were denied. These decisions served as prerequisites for future cases that continually fortified non-white racial classifications. The court decisions determined the definitions of whiteness in the United States.Japanese and United States Relations
In 1894, the same year as In re Saito, the United States and Japan created a trade and immigration treaty called the Treaty of 1894. The treaty created "most-favored-nation” status between Japan and the United States, which was meant to insure that they would have equal trade treatment to what other most-favored-nations received. In the treaty, the United States agreed with the stipulation that all Japanese immigrants in the United States would be granted rights equal to U.S. citizenship.In reality, the United States did not honor these agreements. Many Japanese immigrants in the United States were not allowed the same privileges as citizens. As tensions between white citizens and Japanese immigrant communities increased, Japanese people experienced prejudice and unequal treatment by their white community leaders. In 1906, because of the influence of racist mobs, the San Francisco Board of Education forced the segregation of Japanese children into Asian schools which was a violation of the treaty. This caused a diplomatic rift that led to the Gentleman's Agreement of 1907.