In 1922, Takao Ozawa, a Japanese immigrant who had attended the University of California, also appealed the rejection of his citizenship application. He argued that his skin was physically white and that race shouldn't matter for citizenship. The Supreme Court, however, decided that the Japanese were not legally white based on science, which classified them as Mongoloid rather than Caucasian.


Less than a year later, in the case of United States v. Bhagat Singh Thind, the court contradicted itself by concluding that Asian Indians were not legally white, even though science classified them as Caucasian. Refuting its own reasoning in Ozawa, the justices declared that whiteness should be based not on science, but on "the common understanding of the white man."