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. Yet discriminatory state and federal laws kept him from joining the California bar. APALSA now works to right this historic wrong and gain Mr. Chang’s posthumous admittance to the California state bar.Hong Yen Chang’s Background
In 1872, thirteen-year-old Hong Yen Chang arrived in the United States as part of the Chinese Educational Mission, a program designed to teach Chinese youth about Western culture. Mr. Chang attended Hartford Public High School in Connecticut and then the exclusive Phillips Academy in Andover, Massachusetts. After graduating in 1879, Mr. Chang attended Yale College (now Yale University). When the Chinese government cancelled the Mission in 1881, Mr. Chang was forced to suspend his studies at Yale and return to China.
Nevertheless, Mr. Change came back to the United States and enrolled in Columbia Law School. There, he graduated in 1886 and reportedly became the first Chinese lawyer educated in the United States.
After graduating from Columbia Law School, Mr. Chang applied for admission to the New York state bar. Mr. Chang received high marks from the bar examiners. The New York Supreme Court, however, rejected his application on the ground that he was not a citizen. Undeterred, Mr. Chang reapplied for admission and was successful. 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.
After his admittance to the New York state bar, Mr. Chang applied to the California bar. The California Supreme Court denied 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 non-citizen, he was ineligible for bar membership. Mr. Chang otherwise satisfied the requirements for bar admission, the Court acknowledged. But because federal law barred Chinese immigrants from naturalizing, Mr. Chang could not become a citizen was thus ineligible to practice law in California.
Mr. Chang’s case came in an era of widespread discrimination against people of Chinese ancestry. As mentioned in the Court’s decision, the Chinese Exclusion Act, enacted by Congress in 1882, banned Chinese immigration for ten years and made Chinese residents ineligible to naturalize. Congress extended the Act on a number of occasions. Further, the California Constitution of 1879 dedicated an entire article to restricting the rights of Chinese residents.
Notwithstanding the discrimination he faced, Mr. Chang went on to lead a distinguished career in banking and diplomacy.
Project members: Professor Gabriel "Jack" Chin, Robert Marcelis, Chris Alvarez, Kian Parvaneh, Erin Tanimura, and Tina Wang.
APALSA now calls for Mr. Chang’s admittance to the California state bar. Mr. Chang was qualified for admission in 1890, and the laws blocking him from the practice of law have since been repudiated. Posthumously admitting him now would remedy the injustice he suffered and send a powerful message about the legal profession’s commitment to diversity and inclusion.