The U.S. Supreme Court decided a series of cases in the 1880s and 1890s known collectively as the Chinese Exclusion cases. One of the more important was Chae Chan Ping v. United States (1889), in which the Court upheld an 1888 law, called the Scott Act, which prohibited Chinese laborers from reentering the United States even if they had previously obtained a reentry certificate. The effect of this law was to abolish the certificates of reentry.

Chae Chan Ping was a Chinese laborer who lived in San Francisco for twelve years from 1875 to 1887. He left the United States and then sailed back to San Francisco in 1888. He was denied reentry based on the 1888 law.

The U.S. Supreme Court unanimously upheld the 1888 law, reasoning the government has broad powers in restricting the rights of aliens to enter the country. “That the government of the United States, through the action of the legislative department, can exclude aliens from its territory is a proposition which we do not think open to controversy,” Justice Stephen Field wrote for the Court. “Jurisdiction over its own territory to that extent is an incident of every independent nation.” He added that the government could revoke at any time reentry certificates to aliens “at its pleasure.”