BILL ANALYSIS �
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THIRD READING
Bill No: SR 46
Author: Beall (D), Lieu (D), and Liu (D)
Amended: As introduced
Vote: Majority
SUBJECT : Hong Yen Chang
SOURCE : Author
DIGEST : This resolution calls for Mr. Hong Yen Changs
admittance to the State Bar of California posthumously, to
remedy the injustice he suffered and to send a powerful message
about the legal professions commitment to justice, diversity,
and inclusion.
ANALYSIS : This resolution makes the following legislative
findings:
1.Mr. Hong Yen Chang was reportedly the first Chinese immigrant
to earn a law degree in the United States and the first to be
licensed to practice law in any state, but was denied entry to
the State Bar of California because of discriminatory state
and federal laws.
2.When the Chinese government canceled its Chinese Educational
Mission in 1881, Mr. Chang was forced to suspend his studies
at Yale and return to China but nevertheless, Mr. Chang
returned to the United States, enrolled in Columbia Law School
where he graduated in 1886, and reportedly became the first
Chinese lawyer educated in the United States.
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3.After graduating from Columbia Law School, Mr. Chang applied
for admission to the New York State Bar Association where he
received high marks from the bar examiners.
4.The New York Supreme Court rejected his application on the
ground that he was not a citizen. Undeterred, Mr. Chang
reapplied for admission and was successful.
5.In 1887, the New York Court of Common Pleas issued him a
naturalization certificate, and the state legislature enacted
a law permitting him to reapply to the bar. Upon his
admission, Mr. Chang became the only regularly admitted
Chinese lawyer in the United States.
6.After his admittance to the New York State Bar Association,
Mr. Chang applied to the State Bar of California but the
California Supreme Court denied his admission in the unanimous
published decision In re Hong Yen Chang, 84 Cal. 163 (1890).
The Court held that Mr. Chang's naturalization certificate was
void and that, as a noncitizen, he was ineligible for bar
membership, despite Mr. Chang otherwise satisfying the
requirements for bar admission.
7.Congress extended the Chinese Exclusion Act on a number of
occasions and the California Constitution in 1879 dedicated an
entire article to restricting the rights of Chinese residents.
8.Notwithstanding the discrimination he faced, Mr. Chang went on
to lead a distinguished career in banking and diplomacy.
This resolution calls for Mr. Hong Yen Chang's admittance to the
State Bar of California posthumously to remedy the injustice he
suffered and to send a powerful message about the legal
profession's commitment to justice, diversity, and inclusion.
FISCAL EFFECT : Fiscal Com.: No
AL:nl 5/21/14 Senate Floor Analyses
SUPPORT/OPPOSITION: NONE RECEIVED
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