In re Admin. Order 2017-05-17

Before this court is a motion from the Little Tokyo Historical Society and the Japanese American Bar Association seeking admission to the State Bar of California for Sei Fujii, a Californian who died in 1954. Fujii was born in Japan and immigrated to the United States in 1903. Eight years later, he graduated with a law degree from the University of Southern California. The materials before us contain no indication that Fujii took or passed a bar exam or that he applied for admission to the California bar. But such acts by Fujii would have been futile in light of our decision in In re Hong Yen Chang (1890) 84 Cal. 163 , 24 P. 156 . Federal law at the time limited naturalization solely to " 'free white persons' " and "persons of African descent." ( Ozawa v. United States (1922) 260 U.S. 178 , 180, 43 S.Ct. 65 , 67 L.Ed. 199 .) At the same time, California and most other states prohibited foreign-born persons from practicing law unless they were eligible for citizenship. ( Raffaelli v. Committee of Bar Examiners (1972) 7 Cal.3d 288 , 291, 101 Cal.Rptr. 896 , 496 P.2d 1264 .) This court upheld that restriction in In re Hong Yen Chang and later suggested that noncitizens were too…