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The Fuller Court (1888–1910)

Racial Discrimination

What distinction did the Court make between the Chinese Exclusions cases and the Wong Kim Ark case?

The Court recognized a distinction between Wong Kim Ark and the Chinese Exclusion Cases based on place of birth. The persons denied reentry to the United States in the Chinese Exclusion cases were not born in the United States. The Court pointed out that while Congress may pass laws limiting the status of aliens, the Fourteenth Amendment explicitly provides that all persons born in the United States are citizens.