Nishimura Ekiu v. United States (SCOTUS 1892)

Summary

The Court affirmed the denial of habeas relief to a Japanese immigrant whom an immigration inspector excluded as likely to become a public charge. It held that Congress constitutionally delegated immigration-exclusion authority to executive officers, that the inspector was properly appointed, and that the inspector's authorized factual determination was final except through the statutory administrative appeal. The Court also held that habeas review could determine the lawfulness of detention but could not revisit the merits of the inspector's exclusion decision.

Holding

Appellate jurisdiction. The Supreme Court had appellate jurisdiction because the case involved the constitutionality of a federal law, notwithstanding the effective date of the statute establishing the circuit courts of appeals.

Constitutionality of federal immigration exclusion and executive factfinding. The federal immigration-exclusion statute was constitutional and valid, and Congress could entrust the determination of an alien's right to land to executive immigration officers.

Scope of habeas corpus review and defects in initial detention. Habeas corpus could test whether the petitioner was lawfully detained, but she could not be discharged because of defects in the original arrest or commitment when a valid statutory basis for continued detention was established.

Appointment, procedure, and finality of the immigration inspector's decision. The Secretary of the Treasury lawfully appointed Hatch; the statute did not require the inspector to take testimony or create a record unless testimony was taken; and Hatch's authorized adverse decision was final and conclusive against the petitioner's right to land absent the statutory administrative appeal.

Nishimura Ekiu v. United States

Summary

Holding

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