## Facts

- Sei Fujii, a Japanese citizen then ineligible for U.S. naturalization, purchased California real property in 1948.
- California’s Alien Land Law permitted land ownership by aliens eligible for citizenship, but restricted ownership by aliens ineligible for citizenship absent treaty authorization.
- The statute provided that real property acquired in violation of its restrictions would escheat to the State as of the date of acquisition.
- No treaty between the United States and Japan authorized Fujii to own the land at issue.
- The State filed an action asserting the property escheated under the Alien Land Law; the trial court entered judgment for the State.
- Fujii appealed, arguing (1) the United Nations Charter invalidated the law, and (2) the law violated the Fourteenth Amendment’s Equal Protection Clause.

## Issues

1. Whether the human-rights and non-discrimination provisions of the United Nations Charter are self-executing and directly enforceable in state court to invalidate the Alien Land Law.
2. Whether the Alien Land Law’s classification based on eligibility for citizenship unlawfully denies equal protection by functioning as a racial or nationality-based restriction on property ownership.

## Decision

- The California Supreme Court reversed the escheat judgment.
- The court held the UN Charter provisions invoked were not self-executing and therefore did not, by themselves, invalidate the Alien Land Law.
- The court held the Alien Land Law violated the Equal Protection Clause because its citizenship-eligibility classification operated as an impermissible racial/nationality discrimination without adequate state justification.
- The court declared the Alien Land Law invalid under the Fourteenth Amendment as applied to the challenged restrictions and escheat.

## Legal Principles

- A treaty provision is judicially enforceable without implementing legislation only if it is self-executing; courts assess the signatories’ intent as reflected in the treaty’s text and context.
- Broad, programmatic treaty commitments to “promote” human rights and to pursue future measures generally require legislative implementation and do not create immediate, enforceable domestic rights.
- The Equal Protection Clause protects “persons,” including aliens, against arbitrary state discrimination.
- A state classification framed in facially neutral terms may violate equal protection when it effectively tracks racial/nationality exclusions embedded in federal naturalization eligibility rules and lacks a sufficient state interest.

## Conclusion

The court rejected reliance on the UN Charter as a direct source of enforceable domestic rights but invalidated California’s Alien Land Law on equal protection grounds, reversing the escheat of Fujii’s property because the statute’s citizenship-eligibility scheme functioned as unjustified racial/nationality discrimination.


Sei Fujii v. California, 242 P.2d 617 (Cal. 1952)