In 1884, an amendment was added to the Chinese Exclusion Act of 1882 which required Chinese laborers to obtain re-entry certificates if they left the United States with the intention of returning. This change was made while Chew Heong was abroad, so when he tried to return to the States, he was denied re-entry. In December of 1884, he challenged this denial in federal court, arguing that it violated rights promised in treaties with China that were still in place. While this case may seem like a minor inconvenience for one man, it had much larger implications; as many as 15,000 other Chinese workers had left the United States before the re-entry certificates were issued and would not be allowed to renter if the courts ruled against Chew Heong.
However, the Supreme Court decided with a 7-2 vote in Heong’s favor that the denial of re-entry directly conflicted with a treaty the U.S. had with China, effectively overruling an earlier decision by a lower court. Unless the government had plans to repeal this treaty, they must grant re-entry to Heong and the other Chinese laborers who had been abroad when the certificate legislation had been implemented. This was the first of many Chinese Exclusion Supreme Court cases.
