In 1872, Hong Yen Chang came to this country from China as part of an educational program to teach Chinese youth about the West. Chang graduated from Philips Academy in Andover Massachusetts in 1879, earned his undergraduate degree at Yale, and received his juris doctorate at Columbia Law School in 1886. He applied for admission to the New York Bar, but despite a “high marking” and unanimous recommendations from bar examiners, his admission was rejected because he was not a U.S. citizen. That same year, a New York judge issued Chang a certificate of naturalization, and ultimately Chang was admitted to the New York Bar in 1888, becoming the first recognized “regularly admitted Chinese lawyer in the country.”
Desiring to serve the large Chinese community of San Francisco, Chang moved to California and applied for admission to the California Bar. The California Supreme Court rejected Chang’s application, swiftly holding that Chang’s U.S. citizenship was issued without authority, and, under the Chinese Exclusion Act, courts were expressly forbidden to issue citizenships to any native of China.