IRAC: Sei Fujii v State of California
Issue
Whether or not, the UN Charter has the effect of invalidating the California Alien Land Law, which prohibited aliens not eligible for citizenship from owning lands.
Rule
The signatories to the UN Charter commit themselves to foster world peace by promoting tolerance, respect for treaties and other international laws and universal freedoms, which they will do jointly and on their own to achieve those ends.
Application
The UN Charter does not have the effect of invalidating the Alien Land Law because they are not self-executing. This is evident by the absence of mandatory nature of the language used. Rather, the provisions in issue merely indicated a promise by the signatories to be fulfilled through future actions. Thus, there is a need for states to explicitly pass legislations adopting or giving effect to the aforesaid Charter provisions. Despite this, however, the Court found that the statute in question is invalid because it violated the Fourteenth Amendment, particularly the due process and equal protection clauses. Citing the cases of Oyama v. California, 332 US 633 (1948) and Takashi v. Fish & Game Com, 334 US 410 (1948), which abandoned the dicta in Porterfield v. Webb 263 US 225 (1923), the Court ruled that a classification on the basis of eligibility to citizenship is discriminatory because immigration law and state laws regulating property ownership have different basis for their requirements and the application of one to the other will result in discrimination.
Conclusion
The Court reversed the judgment of the trial court, which escheated his lands to the State.
References
Sei Fujii v. State of California, 38 Cal.2d 718 (1952).
