## Facts

- Chae Chan Ping, a Chinese laborer, lived and worked lawfully in San Francisco from about 1875 to 1887.
- In June 1887, he left for China after obtaining a statutory certificate of return issued under federal Chinese restriction laws, which purported to entitle him to reenter.
- While he was abroad, Congress enacted the Scott Act of 1888, which barred Chinese laborers from entering the United States and invalidated return certificates held by Chinese laborers then outside the country.
- Chae returned to San Francisco in October 1888 aboard the steamship *Belgic* and presented his certificate, but the customs collector denied him permission to land solely because the Scott Act annulled the certificate and barred his reentry.
- Chae remained detained in connection with the government’s exclusion decision and sought release through habeas corpus.

## Issues

1. Whether Congress has constitutional authority to exclude a class of aliens from entering the United States, including those who previously resided lawfully and were permitted by prior law to depart and return.
2. Whether a federal statute may, as domestic law, override rights arguably secured by prior treaties with a foreign nation.
3. Whether a certificate of return issued under prior federal law created a vested right to reenter that Congress could not revoke by later legislation.

## Decision

- The Supreme Court unanimously affirmed the denial of habeas relief and upheld the Scott Act of 1888.
- The Court held that Congress may exclude aliens as an incident of national sovereignty and that determinations about when exclusion is necessary for national interests are committed to the political branches.
- The Court held that, for domestic law purposes, a later federal statute prevails over an earlier inconsistent treaty.
- The Court held that the return certificate did not confer a vested right to reenter that was immune from subsequent congressional repeal or modification.

## Legal Principles

- The federal government’s power to exclude aliens is a sovereign power exercised through Congress, and courts give strong deference to the political branches in exclusion decisions tied to foreign relations and national security.
- Treaties and federal statutes have equal status as domestic law; when they conflict, the later-in-time rule applies and the later enactment controls in U.S. courts.
- Permission to reenter evidenced by a statutory certificate is a revocable privilege subject to later congressional change, not a vested, property-like right protected from subsequent legislation.
- The treaty-making power cannot permanently surrender Congress’s sovereign authority to exclude aliens as a matter of domestic constitutional law.

## Conclusion

The Court sustained Congress’s authority to bar the reentry of Chinese laborers despite prior residence, treaty commitments, and previously issued return certificates, grounding the result in sovereign power over exclusion, the later-in-time rule for statutes and treaties, and broad judicial deference to political-branch judgments in immigration and foreign affairs.


Chae Chan Ping v. United States (The Chinese Exclusion Case), 130 U.S. 581 (1889)