ABSTRACT

A United States Supreme Court decision declares unconstitutional one important provision of the California alien land law and raises doubt as to the basic validity of the act. On certiorari, the United States Supreme Court reversed, primarily on the ground that the application of the presumption deprived the citizen son of equal protection of the laws as guaranteed by the Fourteenth Amendment. The Attorney General of California has interpreted it as ending the practical utility of the alien land law, and has indicated his intention to dismiss all the escheat cases pending before the California courts. The holding of Terrace v. Thompson, that the Congressional classification of aliens into those eligible and those ineligible for naturalization is, in and of itself, a reasonable basis for the discrimination of the alien land laws, was sharply criticized. Further judicial or legislative action is required to bring our law into conformity with our avowed ideals.