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Randall Kennedy, Justice Murphy's Concurrence in Oyama v California: Cussing Out Racism, 74 Tex. L. Rev. 1245 (1996).

Abstract: The Supreme Court case of Oyama v. California (1948) involved an application of the California Alien Land Law in the mid-1940s. This law prohibited aliens ineligible for American citizenship from owning or transferring agricultural land. Barred from owning agricultural property himself, Oyama purchased land for his son, Fred Oyama, a US citizen by birth. California claimed the purchases were a fraudulent evasion of the Alien Land Law and pursued an escheat of the lands. The majority opinion invalidated the statute as applied. Justice Frank Murphy, in a 24-page concurrence, places the case in context of the history of anti-Japanese racism and notes the manifold ways in which that bigotry manifested itself in the legal controversy.