PALSU.S. Supreme Court (Justice Field), 1889draftborradorunverifiedsin verificar

Chae Chan Ping v. United States (The Chinese Exclusion Case)

130 U.S. 581 (1889)

A laborer's return certificate canceled by Congress while he sails home

In one lineEn una línea: Congress may exclude foreigners as an incident of sovereignty, and a later statute prevails over an earlier treaty.El Congreso puede excluir extranjeros como atributo de la soberanía, y una ley posterior prevalece sobre un tratado anterior.
RuleRegla: The power to exclude foreigners belongs to the political branches as an incident of national sovereignty; when a statute conflicts with an earlier treaty, the statute controls (last in time), and a certificate issued under prior law creates no vested right against later legislation.
Why this case is herePor qué está aquí este caso: The origin of the plenary power doctrine: Congress controls the admission of foreigners as an attribute of sovereignty, and a later statute beats an earlier treaty.
Procedural posturePostura procesal: Denied entry at San Francisco, he petitioned for habeas corpus; the circuit court denied the writ; the Supreme Court affirmed.

Facts

Chae Chan Ping, a Chinese laborer who had lived in San Francisco since 1875, left for China in 1887 holding a government certificate that entitled him to return under the Chinese Exclusion Act of 1882 as amended. While he was abroad, Congress passed the Scott Act of 1888, which annulled such certificates. On his return he was refused landing.

Procedural posture

He petitioned for a writ of habeas corpus in the federal circuit court, which denied it. He appealed to the Supreme Court, which affirmed.

Issue

Whether Congress could bar his re-entry despite the treaty with China and the certificate issued under the earlier statute.

Holding

Yes. The exclusion was valid; the certificate conferred no vested right and the later statute displaced the treaty as domestic law.

Reasoning

Every sovereign nation has the power to exclude foreigners; in the United States that power rests with the political branches and is not subject to judicial control. Treaties and statutes stand on the same footing, so the later enactment governs. The certificate was a license revocable by Congress. Any breach of the treaty was a matter for diplomacy, not the courts.

Rule (own words)

Immigration control is a sovereign power exercised by Congress with little judicial review, and a later statute overrides an inconsistent earlier treaty.

What-ifs

Compare Elk v. Wilkins from the same week: both cases draw the line of membership in the political community narrowly.
Later cases (Yamataya, Zadvydas) added due process limits for people already inside the country.

Likely follow-upsRepreguntas probables

Why did the treaty with China not protect him?

Treaties and statutes are of equal rank under the Supremacy Clause; the later one governs. The 1888 Scott Act came after the treaty, so it controlled domestically, whatever the international consequences.

What role did the courts leave for themselves?

Almost none: the Court said the political branches' judgment on excluding foreigners is conclusive on the judiciary.

Does this doctrine still matter?

Yes. Plenary power still frames immigration cases, though later decisions added procedural due process for people inside the country and some limits on discrimination.

plenary power (immigration)treaty and the last-in-time rule habeas corpus

AssignedAsignado: 2026-10-16

Read the public opinionLeer la opinión (texto público). SourceFuente: Own brief from the public opinion; handout for Oct 16.