Supreme Court of California

Hong Yen Chang is granted posthumous admission as an attorney and counselor at law in all courts of the state of California, where: 1) Chang graduated from Columbia Law School in 1886; 2) in 1887, a New York judge issued Chang a certificate of naturalization, and Chang was admitted to the New York Bar in 1888, becoming the only regularly admitted Chinese lawyer in the country; 3) upon relocation to California, Chang was denied admission to the California Bar on the basis that former Code of Civil Procedure section 279 provided that only US citizens or persons "who have bona fide declared their intention to become such in the manner provided by law" could gain admission to the Bar upon presentation of a license to practice from another state; 4) this court found that the certificate of naturalization that Chang had obtained in New York was issued without authority of law, and was void under the federal Chinese Exclusion Act, as Chang was "a person of Mongolian nativity"; and 5) the discriminatory exclusion of Chang from the State Bar of California was a grievous wrong that denied him equal protection of the laws, and apart from his citizenship, he was by all accounts qualified for admission to the bar.

Appellate Information

• Decided 03/16/2015
• Published 03/16/2015

Judges

Court

• Supreme Court of California

Counsel