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Dow v. United States
''Dow v. United States'' is a United States Court of Appeals, Fourth Circuit case in which a Syrian immigrant, George Dow, appealed two lower court decisions denying his application for naturalization as a United States citizen.〔Naff, Alixa. Becoming American: the Early Arab Immigrant Experience. Carbondale: Southern Illinois UP, 1985. Print., p. 257〕 Following the lower court decisions in ''Ex Parte Dow'' (1914) and ''In re Dow'' (1914), Dow v. United States resulted in the Circuit Court’s affirmation of the petitioner’s right to naturalize based, in the words of Circuit Judge Woods, on “the generally received opinion . . . that the inhabitants of a portion of Asia, including Syria, () to be classed as white persons”.〔Dow v. United States. Circuit Court of Appeals, Fourth Circuit. 14 Sept. 1915. Nexis Lexis Academic. Web. 28 Sept. 2011., p. 7〕
George Dow’s gauntlet through the American legal system, and the language with which his petition for citizenship was dealt, illustrate the degree to which legal bodies struggled to classify new groups of immigrants in a racial schema which would ultimately determine these immigrants’ right to become American citizens.
==Race-Based Immigration Law before Dow v. United States==
Racial limitations to American immigration originated with the Naturalization Act of 1790, which defined eligibility for citizenship as confined to “any alien, being a free white person who shall have resided within the limits . . . of the United States for a term of two years”.〔Lopez, Ian H. White by Law: the Legal Construction of Race. New York: New York UP, 2006. Print., p. 31〕 While the abolition of slavery resulted in a codicil to this policy in 1870, granting people “of African nativity or African descent” the right to naturalize, a series of prohibitive laws including the Page Law of 1875, the Asian Exclusion Act of 1882, and the Alien Contract Labor Law of 1885 further restricted immigration from Asia based on race and class ideology.〔Lee, Erika. "The Chinese Exclusion Example: Race, Immigration, and American Gatekeeping, 1882-1924." Journal of American Ethnic History Spring 21.3 (2002): 36-62.JSTOR. Web. 29 Sept. 2011., p. 36〕 The Asian Exclusion Act, as noted by Erika Lee, is remarkable for “establish() Chinese—categorized by their race, class, and gender relations as the ultimate category of undesirable immigrants—as the models by which to measure the desirability (and “whiteness”) of other immigrant groups".〔Lee, Erika. "The Chinese Exclusion Example: Race, Immigration, and American Gatekeeping, 1882-1924." Journal of American Ethnic History Spring 21.3 (2002): 36-62.JSTOR. Web. 29 Sept. 2011., p. 37,〕 It is precisely this metric of “whiteness” which would be contested in dozens of court cases asserting the right of immigrants who did not fit neatly into a black/white racial schema to naturalize.
抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』
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