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.
In 1972, the California Supreme Court held that it was unconstitutionally indefensible to forbid noncitizens to practice law. On March 16, 2015, more than a century after Chang’s admission to the Bar was rejected, through the efforts of Chang’s descendants and the Asian Pacific American Law Students Association at the University of California, Davis School of Law, the California Supreme Court reversed its ruling, and granted posthumous admission to Mr. Chang as an attorney in In Re Chang, 14 C.D.O.S. 2614.
“Even if we cannot undo history, we can acknowledge it and, in so doing, accord a full measure of recognition to Chang’s path-breaking efforts to become the first lawyer of Chinese descent in the United States. The people and the courts of California were denied Chang’s services as a lawyer. But we need not be denied his example as a pioneer for a more inclusive legal profession. In granting Hong Yen Chang posthumous admission to the California bar, we affirm his rightful place among the ranks of persons deemed qualified to serve as an attorney and counselor at law in the courts of California.”
This case is further proof that, indeed, as the saying goes, the arc of the moral universe is long, but it bends towards justice. Welcome to the Bar, Mr. Chang. At long last.