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A “Practically American” Canadian Woman Confronts a United States Citizen-Only Hiring Law: Katharine Short and the California Alien Teachers Controversy of 1915

Published online by Cambridge University Press:  26 August 2021

Brendan A. Shanahan
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Abstract

In February 1915, non-citizen teachers throughout California abruptly learned that they would soon lose their jobs when state officials announced that local and county governments were required to enforce a long-forgotten anti-alien public employment law. In response, one Canadian immigrant teacher, Katharine Short, launched a diplomatic, legal, political, and public relations campaign against the policy. Earning the support of powerful (Anglo-)Canadian nationalists in wartime and a favorable depiction in California news coverage as a “practically American” Canadian woman, Short’s efforts culminated in an exemption for most immigrant teachers from the state’s nativist public employment policies. This article recovers, recounts, and contextualizes the California Alien Teachers Controversy of 1915 at the center of transformations in the political development, law, and politics of American citizenship and citizenship rights from the late-nineteenth to mid-twentieth centuries. It testifies to the growing power and powers of state governments to shape immigrants' lives and livelihoods via alienage law long into the mid-twentieth century, the rhetorical strength and courtroom limits of “right to contract” arguments in the context of anti-alien hiring and licensure disputes, and the disparate impact of these nativist laws on immigrants owing to inequalities of race, gender, and class and how those inequalities shaped the less-than-inclusive aims and strategies of Katharine Short in her campaign to alter the state's nativist public employment policies.

Type
Original Article
Information
Law and History Review , Volume 39 , Issue 4 , November 2021 , pp. 621 - 647
Copyright
Copyright © The Author(s), 2021. Published by Cambridge University Press on behalf of the American Society for Legal History

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Footnotes

He thanks the: American Society for Legal History/Cromwell Foundation's Early Career Scholar Fellowship, UC Berkeley Institute for Governmental Study's Fred Martin Award and Mike Synar Fellowship, the UC San Diego's Center for Comparative Immigration Studies – California Immigration Research Initiative Fellowship, and the Center for the Study of Representative Institutions for their research support, which made this article possible. He thanks all readers of previous drafts of this article, especially Khalil Anthony Johnson, Emma Teng, Gabriel Lee, Erin Trahey, and the anonymous reviewers for their feedback. He also thanks the Western History Association Conference and the Society for Legal History Annual Meeting for providing avenues to present on earlier versions of this piece.

References

1 Katharine Short to William Short, February 28, 1915. Library and Archives Canada/ Bibliothèque et Archives Canada, Ottawa, Ontario. RG 25 Vol. 1161, File 671, “Employment of Aliens in California – State Law” (hereafter LAC/BAC, “Employment of Aliens in California”); and Hiram Johnson to William Jennings Bryan, April 6, 1915, 2–3. Bancroft Library and Archives, Berkeley, California. Hiram Johnson Papers, MSS C-B 581 Part II, Box 3, “Letters from Johnson, April 1914–July 1915” (hereafter BANC, “Letters from Johnson”).

2 See subsequent footnotes for relevant citations.

3 Milton Konvitz counted 495 such state policies in force in 1946. See Milton Konvitz, The Alien and the Asiatic in American Law (Ithaca, NY: Cornell University Press, 1946), 208–9.

4 Alexandra Filindra, “E Pluribus Unum? Federalism, Immigration and the Role of the American States” (PhD diss., Rutgers University, 2009), 128–52; and Scott, Jessye Leigh, “Alien Teachers: Suspect Class or Subversive Influence,” Mercer Law Review 31 (1980): 815–24Google Scholar.

5 Konvitz, The Alien and the Asiatic, 172.

6 Kelly, Michael Cornelius, “A Wavering Course: United States Supreme Court Treatment of State Laws Regarding Aliens in the Twentieth Century,” Georgetown Immigration Law Journal 25 (2011): 701–40Google Scholar.

7 Fields, Harold, “Where Shall the Alien Work?” Social Forces 12 (1933): 213–21CrossRefGoogle Scholar.

8 This author briefly addresses this dispute in his dissertation “Making Modern American Citizenship: Citizens, Aliens, and Rights, 1865–1965” (PhD diss., University of California, Berkeley, 2018), which he is currently revising into a monograph. In solidarity with recent practices to eschew the use of the term “alien” as a noun to describe individuals or groups of people, this article instead employs “non-citizen” when possible. The text retains the use of “alien,” however, within quotations, as an adjective to describe alienage law, and as the title of the controversy itself.

9 Key works include: Mary Anne Thatcher, Immigrants and the 1930s: Ethnicity and Alienage in Depression and On-Coming War (New York: Garland, 1990); Bloemraad, Irene, “Citizenship Lessons from the Past: The Contours of Immigrant Naturalization in the Early 20th Century,” Social Science Quarterly 87 (2006): 927–953CrossRefGoogle Scholar; and Catron, Peter, “The Citizenship Advantage: Immigrant Socioeconomic Attainment in the Age of Mass Migration,” American Journal of Sociology 124 (2019): 999–1042CrossRefGoogle Scholar.

10 See, among many others, Karen Isaksen Leonard, Making Ethnic Choices: California's Punjabi Mexican Americans (Philadelphia: Temple University Press, 1992); and Suzuki, Masao, “Important or Impotent? Taking Another Look at the 1920 California Alien Land Law,” Journal of Economic History 64 (2004): 125–43CrossRefGoogle Scholar.

11 See, among others: David Fellman, “The Alien's Right to Work,” Minnesota Law Review 22 (1938): 137–76; Konvitz, The Alien and the Asiatic; David Carliner, The Rights of Aliens: The Basic ACLU Guide to an Alien's Rights (New York: Avon Books, 1977); and Hiroshi Motomura, Americans in Waiting: The Lost Story of Immigration and Citizenship in the United States (New York: Oxford University Press, 2006); and Kelly, “Wavering Course.”

12 As Kunal Parker argues, United States historians rarely examine “the way citizenship has functioned ‘negatively’ vis-à-vis resident aliens.” Kunal Parker, Making Foreigners: Immigration and Citizenship Law in America, 1600–2000 (New York: Cambridge University Press, 2015), 233.

13 John Higham, Strangers in the Land: Patterns of American Nativism, 1860–1925 (New York: Atheneum, 1963), see especially: 46–47, 72–73, 183–84; and Gwendolyn Mink, Old Labor and New Immigrants in American Political Development: Union, Party, and State, 1875–1920 (Ithaca, NY: Cornell University Press, 1986), see especially 123.

14 Cybelle Fox, Three Worlds of Relief: Race, Immigration, and the American Welfare State from the Progressive Era to the New Deal (Princeton: Princeton University Press, 2012), 156–87, 214–49.

15 Filindra, “E Pluribus Unum?” 30.

16 See, among many others, Jon Teaford, The Unheralded Triumph: City Government in America, 1870–1900 (Baltimore: Johns Hopkins University Press, 1984); Steven Erie, Rainbow's End: Irish-Americans and the Dilemmas of Urban Machine Politics, 1840–1985 (Berkeley: University of California Press, 1988); and Law, Marc T. and Kim, Sukkoo, “Specialization and Regulation: The Rise of Professionals and the Emergence of Occupational Licensing Regulation,” Journal of Economic History 65 (2005): 723–56CrossRefGoogle Scholar.

17 Joo, Thomas Wuil, “New ‘Conspiracy Theory’ of the Fourteenth Amendment: Nineteenth Century Chinese Civil Rights Cases and the Development of Substantive Due Process Jurisprudence,” University of San Francisco Law Review 29 (1995): 353–88Google Scholar; and Charles J. McClain, In Search of Equality: The Chinese Struggle Against Discrimination in Nineteenth-Century America (Berkeley: University of California Press, 1994).

18 William E. Forbath, Law and the Shaping of the American Labor Movement (Cambridge, MA: Harvard University Press, 1991); and Amy Dru Stanley, From Bondage to Contract: Wage Labor, Marriage, and the Market in the Age of Slave Emancipation (New York: Cambridge University Press, 1998).

19 Kelly, “Wavering Course,” 704–8; and Motomura, Americans in Waiting, 68–70.

20 See Maddalena Marinari, Unwanted: Italian and Jewish Mobilization against Restrictive Immigration Laws, 1882–1965 (Chapel Hill: University of North Carolina Press, 2020).

21 “Would Relieve Alien Teachers,” Los Angeles Times, March 28, 1915, I7.

22 Anglo Canadians were universally understood to be white by law and in practice in United States society in the early-to-mid twentieth century. By contrast, as sociologists Cybelle Fox and Irene Bloemraad emphasize, Mexican immigrants, then disproportionately likely to encounter blue-collar anti-alien public employment restrictions in California, were widely viewed as non-white despite their status as white under federal nationality law. See Fox, Cybelle and Bloemraad, Irene, “Beyond ‘White by Law’: Explaining the Gulf in Citizenship Acquisition between Mexican and European Immigrants, 1930,” Social Forces 94 (2015): 181–207CrossRefGoogle Scholar; Meanwhile, although Italian immigrant men, inordinately likely to encounter contemporaneous blue-collar nativist hiring laws on the East Coast and in the Midwest, were far more frequently recognized as “white by law,” they were rarely, if ever, viewed as “practically American,” like Short. See, among many others, Luconi, Stefano, “Black Dagoes? Italian Immigrants’ Racial Status in the United States: An Ecological View,” Journal of Transatlantic Studies 14 (2016): 188–99CrossRefGoogle Scholar.

23 See, among many others, Alexander Saxton, The Indispensable Enemy: Labor and the Anti-Chinese Movement in California (Berkeley: University of California Press, 1971); Mink, Old Labor and New Immigrants, 71–112; Joo, “New Conspiracy Theory”; McClain, In Search of Equality; Motomura, Americans in Waiting, 63–95; and Beth Lew-Williams, The Chinese Must Go: Violence, Exclusion, and the Making of the Alien in America (Cambridge, MA: Harvard University Press, 2018).

24 On these comparisons in immigration restrictionist politics, see especially Lee, Erika, “The Chinese Exclusion Example: Race, Immigration, and American Gatekeeping, 1882–1924,” Journal of American Ethnic History 21 (2002): 36–62Google Scholar. On these analogies in racialized labor politics, see, among others, Donna Gabaccia, “The ‘Yellow Peril’ and the ‘Chinese of Europe’: Global Perspectives on Race and Labor, 1815–1930,” in Migration, Migration History, History: Old Paradigms and New Perspectives, ed. Leo Lucassen and Jan Lucassen (New York: Peter Lang, 1997), 177–96; and Luconi, “Black Dagoes?”.

25 On building trades union support for one such law in Illinois, see, among others, Rudolph Vecoli, “Chicago's Italians Prior to World War I: A Study of Their Social and Economic Adjustment” (Ph.D. diss., University of Wisconsin, Madison, 1963), 417–22; For references to these three states’ laws, see Higham, Strangers in the Land, 46; Mink, Old Labor and New Immigrants, 123; and Amy Bridges, Democratic Beginnings: Founding the Western States (Lawrence: University Press of Kansas, 2015), 96–97.

26 Ch. 380 (1889) New York – 112nd Legislature: 508.

27 On the New York and Pennsylvania laws, see Higham, Strangers in the Land, 72–73; and Mink, Old Labor and New Immigrants, 123. See also Ch. 202 (1899) New Jersey Legislature – 123rd Session: 524–25.

28 Act 347 (1895) – Massachusetts General Court: 389–90; Act 488 (1895) – Massachusetts General Court: 565–82; and Act 494 (1896) – Massachusetts General Court: 492.

29 Higham, Strangers in the Land, 46; Mark Wyman, Round-Trip to America: The Immigrants Return to Europe, 1880–1930 (Ithaca, NY: Cornell University Press, 1993), 103–4; and Paul Moses, An Unlikely Union: The Love-Hate Story of New York's Irish and Italians (New York University Press, 2015), 73–81.

30 Failed anti-alien public hiring bills included, AB 575: Journal of the Assembly, 32nd Session, State of California (Sacramento: State Printing Office, 1897), 225; and AB 393: Journal of the Senate, 33rd Session, State of California (Sacramento: State Printing Office, 1899), 1113. On these and other anti-alien hiring proposals (and labor support for them) see “No Alien May Do Public Work: The California Labor Convention Favors American Citizens,” San Francisco Call, October 26, 1896, 12; “Labor Convention Adjourns Sine Die,” San Francisco Chronicle, March 22, 1897, 11; and “None But Citizens Can Get Work,” San Francisco Call, January 22, 1899, 3–4.

31 Journal of the Assembly, 34th Session, State of California (Sacramento: State Printing Office, 1901), 597; and Journal of the Senate, 34th Session, State of California (Sacramento: State Printing Office, 1901), 1050. See also: “Governor Gage Exercises the Rights of His Office,” San Jose Mercury News, February 21, 1901, 1; and “Bills Made Law by Governor Gage,” Los Angeles Herald, March 29, 1901, 4.

32 Ch. 185 (1901) California Legislature – 34th Session: 589.

33 See, as examples, “Work on County Roads: The Contracting Firms Are Obliged to Employ Aliens,” Pittsburgh Gazette, October 15, 1897, 5; and “City Contract Labor Sixty Per Cent. Alien,” New York Times, April 18, 1905, 6.

34 See especially the work of Robert B. Ross, “Scales and Skills of Monopoly Power: Labor Geographies of the 1890–1891 Chicago Carpenters’ Strike,” Antipode 43 (2011): 1281–304.

35 People v. Warren 13 Misc. 615, 34 N.Y.S. 942 (1895).

36 City of Chicago v. Hulbert 205 Ill. 346, 68 N.E. 786 (1903) in: Lindley Clark, “Labor Laws Declared Unconstitutional,” Bulletin of the Bureau of Labor 21 (1910): 933.

37 “Canadian Teachers Classed as Aliens,” Ottawa Citizen, March 15, 1915, 6.

38 “Alien Law Decision Halts New Subways,” New York Times, February 27, 1915, 5.

39 New York Bureau of Statistics of Labor, Thirteenth Annual Report of the for the Year 1895, Vol. 1 (Albany: Wynkoop Hallenbeck Crawford, Co., State Printers, 1896), 543; and “Water Board Blamed,” Boston Herald, July 11, 1900, 16.

40 This author explores the contested implementation of these laws in other states in two chapters of his longer book manuscript project, tentatively entitled, Citizenship Rights or Citizen-Only Rights? Nativist Politics, Alienage Law, and the Invention of American Citizenship Rights, 1865–1965. For one example of layoffs arising from the administration of a state anti-alien public works hiring law, see “Cannot Employ Aliens,” Chicago Daily Tribune, March 12, 1891, 6.

41 Louisiana and Arizona joined the ranks of these eight other states in 1908 and 1912, respectively. See Act. 271 (1908) Louisiana – General Assembly: 398–99; and Ch. 66 (1912) Arizona – 1st State Legislature, Special Session: 188–94.

42 On the history of “first papers” and their denial to East and South Asian immigrants, see especially Motomura, Americans in Waiting.

43 See, among many others, Herbert Le Pore, “Prelude to Prejudice: Hiram Johnson, Woodrow Wilson, and the California Alien Land Law Controversy of 1913,” Southern California Quarterly 61 (1979): 99–110; and Motomura, Americans in Waiting, 69–70, 75–76.

44 See, among several others, Astrid J. Norvelle, “‘80 Percent Bill,’ Court Injunctions, and Arizona Labor: Billy Truax's Two Supreme Court Cases,” Western Legal History 17 (2004): 163–210; and Katherine Benton-Cohen, Borderline Americans: Racial Division and Labor War in the Arizona Borderlands (Cambridge, MA: Harvard University Press, 2009), 200–205.

45 New York Public Service Commission, Report of the Public Service Commission for the First District of the State of New York for the Year Ending December 31, 1914 (Albany, NY: 1915), 92–94; see also Higham, Strangers in the Land, 183–84; and Catron, “The Citizenship Advantage,” 1005.

46 “Alien Labor Ban May Tie Up All Transit Work,” New York Tribune, November 18, 1914, 1; “The New York Alien Labor Law,” New York Times, November 19, 1914, 10; “Grout Seeking Test of Alien Labor Law,” New York Times, November 21, 1914, 6; and “Alien Law Decision Halts New Subways,” 5.

47 “General Alien Laws Opposed by President,” St. Louis Post-Dispatch, December 15, 1914, 3; and “Can't Stop Anti-Alien Laws,” New York Times, December 16, 1914, 10.

48 The case would ultimately reach the Supreme Court in: Truax v. Raich, 239 U.S. 33 (1915). On its broader legal and political context, see, especially, Norvelle, “‘80 Percent Bill,’ Court Injunctions, and Arizona Labor,” 183–94.

49 These cases would also ultimately reach the nation's highest court. See Heim v. McCall, 239 U.S. 175 (1915) and Crane v. New York 239 U.S. 195 (1915).

50 “Court Upholds Alien Labor Law,” New York Times, February 26, 1915, 1, 5; and “Alien Law Decision Halts New Subways,” 5.

51 “Alien Law Repeal Passes the Senate,” New York Times, March 9, 1915, 1; and “May Keep Aliens on Subway Work,” New York Times, April 5, 1915, 9.

52 Johnson to Bryan, April 6, 1915, 2. BANC, “Letters from Johnson.”

53 Johnson to Bryan, April 6, 1915, 2–3. BANC, “Letters from Johnson.” See also: “Aliens Barred from Teaching Public Schools,” (Santa Rosa) Press Democrat, February 6, 1915, 1; and “Teachers Aroused by Webb Ruling,” Daily Colusa Sun, February 10, 1915, 1. Webb was a co-author of the 1913 Alien Land Act. See Le Pore, “Prelude to Prejudice.”

54 “Alien Teacher Out,” Los Angeles Times, February 15, 1915, II6; and “School Disrupted by Alien Teacher,” Sacramento Union, April 2, 1915, 12.

55 “Alien Teachers Appeal to Hyatt,” Daily Colusa Sun, March 19, 1915, 1; and “Alien Teacher Salaries Held in Santa Barbara,” Los Angeles Times, April 2, 1915, I7.

56 “Alien Teachers’ Salaries Held Up by the Trustees,” San Francisco Chronicle, March 19, 1915, 1.

57 “Many Teachers in State Ineligible,” Sacramento Union, February 19, 1915, 8.

58 “Alien Teachers Appeal to Hyatt,” 1.

59 “Alien Teachers in Law Trouble,” San Francisco Chronicle, March 20, 1915, 7.

60 “Alien Teachers Ask Hyatt for Warrants,” Los Angeles Herald, March 19, 1915, 12.

61 “Alien Teachers Ask How to Hold Place,” Los Angeles Herald, February 18, 1915, 10.

62 “Teachers Are to Be Citizens,” (Santa Rosa) Press Democrat, March 17, 1915, 6.

63 “Alien Teachers Getting Papers Naturalization,” Red Bluff Daily News, April 27, 1915, 4.

64 “Big Rush of Aliens to Become Citizens,” New York Times, December 13, 1914, 11; and Norvelle, “‘80 Percent Bill,’ Court Injunctions, and Arizona Labor,” 188.

65 In 1915, only women racially ineligible for citizenship (i.e., East and South Asian women) retained their nationality upon marrying U.S. citizen husbands. See Marian L. Smith, “‘Any Woman Who Is Now or May Hereafter Be Married . . .’: Women and Naturalization, ca. 1802-1940,” Prologue 30 (1998): 146–53.

66 “100 Teachers Must Wed to Keep Jobs,” Los Angeles Evening Herald, February 19, 1915, 9.

67 “100 Men Wanted To Qualify as Able to Wed,” Los Angeles Evening Herald, February 23, 1915, 9.

68 On marital expatriation, see especially Candice Lewis Bredbenner, A Nationality of Her Own: Women, Marriage, and the Law of Citizenship (Berkeley: University of California Press, 1998).

69 “Alien Teachers in Law Trouble,” 7.

70 “Alien Teachers in State Are Denied Money Is Charge,” San Francisco Chronicle, March 16, 1915, 3; and “Alien Teachers in Law Trouble,” 7.

71 Katharine Short to William Short, February 28, 1915. LAC/BAC, “Employment of Aliens in California.”

72 “Suit Threatened Over Alien Teacher Trouble,” Ukiah Dispatch Democrat, February 26, 1915; and “Alien Teachers Appeal to Hyatt,” 1. The author thanks the Mendocino County Historical Society, and especially Archivist Alyssa Ballard, for tracking down and sharing several local newspaper accounts (from the Ukiah Dispatch Democrat and the Mendocino Beacon) of Katharine Short's dispute from records held by the MCHS.

73 See “William Gray,” Parliament of Canada Biography, https://lop.parl.ca/sites/ParlInfo/default/en_CA/People/Profile?personId=13112 (May 13, 2021).

74 Quote from William Short to William Gray, March 10, 1915. LAC/BAC, “Employment of Aliens in California.” See also Carolyn Peter, “California Welcomes the World: International Expositions, 1894–1940 and the Selling of the State,” in Reading California: Art, Image, and Identity, 1900–2000, ed. Stephanie Barron, Sheri Bernstein, and Ilene Susan Fort (Berkeley: University of California Press, 2000), 69–84.

75 Johnson to Bryan, April 6, 1915, 5. BANC, “Letters from Johnson.”

76 See, among others, “Dominion Asked to Secure Rights for Canadians,” (London) Free Press, March 10, 1915, in LAC/BAC, “Employment of Aliens in California”; “Refusing to Pay Canadians,” Ottawa Citizen, March 19, 1915, 3; “Californian Law,” The Scotsman, March 18, 1915, 5; “Canadians’ Pay Withheld,” Rochester Democrat and Chronicle, March 16, 1915, 2; “Says Canadians Not Paid,” Boston Daily Globe, March 16, 1915, 13; and “Education Bill Causes a Row,” Los Angeles Times, March 18, 1915, I5.

77 E.L. Newcombe to Joseph Pope, March 15, 1915; and Gray to Pope, March 16, 1915. LAC/BAC, “Employment of Aliens in California.”

78 Kendrick A. Clements, “Manifest Destiny and Canadian Reciprocity in 1911,” Pacific Historical Review 42 (1973): 32–52; and John Herd Thompson and Stephen J. Randall, Canada and the United States: Ambivalent Allies (Athens: University of Georgia Press, 2002), 87–92.

79 World War I also split mostly pro-war Anglo-Canadian and largely pro-neutrality French-Canadian communities. See Thompson and Randall, Canada and the United States, 92–98.

80 House of Commons Debates, 12th Parliament, 5th Session, Vol. 2: March 18, 1915, 1190.

81 Ibid., 1191.

82 The British ambassador represented Canadian interests in Washington, DC, until the opening of a Canadian legation in 1927. See Stephen Azzi, Reconcilable Differences: A History of Canada-US Relations (New York: Oxford University Press, 2014), 105.

83 Prince Arthur to Spring Rice, April 1, 1915. LAC/BAC “Employment of Aliens in California.”

84 Formal Correspondence of Spring Rice to Bryan, March 24, 1915, 1–2; and Personal Correspondence of Spring Rice to Bryan, March 24, 1915, 1–3. LAC/BAC, “Employment of Aliens in California.”

85 Personal Correspondence, March 24, 1915, 2. LAC/BAC, “Employment of Aliens in California.”

86 Bryan to Johnson, March 29, 1915, 1–2. BANC Hiram Johnson Papers, MSS C-B 581 Part II, Box 34, “Letters to Johnson, UI-VZ,” Folder, “U.S. State Department, January-December 1915,” (hereafter BANC, “Letters to Johnson”); See also “Bryan Comes to Rescue of Alien Teachers,” Los Angeles Times, April 1, 1915, I3.

87 Johnson to Bryan, March 30, 1915, 1–3. BANC, “Letters from Johnson.”

88 Le Pore, “Prelude to Prejudice.”

89 Johnson to Bryan, March 31, 1915, 1. BANC, “Letters from Johnson.”

90 Ibid., 2. See also “Alien Enemies in Public Positions,” Canada Law Journal LI (1915): 5. Found in LAC/BAC “Employment of Aliens in California.”

91 “Paraphrase of cypher telegram from the Ambassador at Washington to the Governor-General,” April 3, 1915; and Spring Rice to Prince Arthur, April 14, 1915. LAC/BAC “Employment of Aliens in California.”

92 Newcombe to Pope, April 14, 1915. LAC/BAC, “Employment of Aliens in California.”

93 Spring Rice to Pope, April 24, 1915. LAC/BAC, “Employment of Aliens in California.”

94 Pope to Newcombe, May 12, 1915, 1. LAC/BAC, “Employment of Aliens in California.”

95 Ibid., 2.

96 Johnson to Bryan, April 6, 1915, 5. BANC, “Letters from Johnson.”

97 Ibid., 5.

98 Ibid., 6.

99 “Regarding Alien Teachers,” Mendocino Beacon, February 27, 1915; In Santa Barbara County, the Lompoc Journal similarly lambasted the abrupt, unwanted firing of a popular (also Canadian) grammar school principal in the middle of the academic year. See “Alien Law Hits Local School Teacher,” Lompoc Journal, March 13, 1915, 1.

100 “Why Alien Teachers?” (Santa Barbara) Morning Press, April 4, 1915, 4.

101 “Teachers Affected by California Law,” Ottawa Citizen, April 3, 1915, 5; “Forgotten Law Is Invoked to Oust Teachers,” Arizona Republican, April 1, 1915, 1, 5; and “Protests Dismissal of Canadians in California,” Detroit Free Press, April 3, 1915, 9.

102 For examples of such press coverage, see “No Alien School Teachers,” Sacramento Union, February 7, 1915, 4; “Surprising Ignorance,” Riverside Daily Press, May 28, 1915, 4; and “The Naturalization of School Teachers,” Los Angeles Herald, May 31, 1915, 6.

103 Only at the very end of the dispute did Deputy Minister of Justice E.L. Newcombe clarify that Ontario did indeed have a similar citizen-only public schoolteacher law. However, he insisted that unlike officials in Mendocino, authorities in Ontario would have paid the salary of a mistakenly hired non-citizen teacher. See Newcombe to Pope, April 14, 1915; Newcombe to Pope, May 22, 1915. LAC/BAC, “Employment of Aliens in California.”

104 Robert Lansing to Johnson, April 20, 1915, 2. “U.S. Department of State, January–December 1915,” BANC, “Letters to Johnson.”

105 “Why Alien Teachers?” 4.

106 “Would Relieve Alien Teachers,” I7.

107 “Johnson Is Opposed to Speeders,” Hanford Journal, March 28, 1915, 1; “Bill to Aid Alien Teachers Approved,” San Francisco Chronicle, April 2, 1915, 3; “Assembly Approves Exemption of Aliens,” San Francisco Chronicle, April 20, 1915, 1; and “First Papers Entitle Aliens to Teach in Public Schools,” Sacramento Union, May 17, 1915, 10.

108 Katharine Short to Ministry of Justice, May 26, 1915. LAC/BAC, “Employment of Aliens in California.”

109 Motomura, Americans in Waiting, 69.

110 Kelly, “Wavering Course,” 704–8.

111 Ibid.

112 Ch. 417 (1915) California Legislature – 41st Session: 690–91.

113 See especially Ian Haney-López, White by Law: The Legal Construction of Race (New York University Press, 1996); and Smith, “‘Any Woman Who Is Now Now or May Hereafter Be Married.’”

114 Martha Menchaca, Naturalizing Mexican Immigrants: A Texas History (Austin: University of Texas Press, 2011); and Fox and Bloemraad, “Beyond ‘White by Law.’”

115 “Cannot Employ Aliens,” (San Luis Obispo) Morning Tribune, February 24, 1915, 1.

116 “Alien Janitors Barred from School Service,” Sacramento Union, April 15, 1915, 9; “Old Alien Labor Law to Get Riverside into Spot Light,” Riverside Daily Press, April 26, 1915, 6; and “Native Laborers Replacing Aliens,” Riverside Daily Press, May 1, 1915, 2.

117 “Old Alien Labor Law to Get Riverside into Spot Light,” 6.

118 “Native Laborers Replacing Aliens,” 2.

119 Meeting Minutes, May 20, 1918. California State Archives, Sacramento. California Board of Education, “Commission on Credentials Minutes, 1918–1929,” Files 359.01 (1–2) C3609.

120 “Poison in the Spring,” Los Angeles Times, November 23, 1919, II4.

121 Meeting Minutes, February 17, 1942. California State Archives. Board of Education, “Teacher Preparation and Licensing Commission – Credentials Commission, 1/19/1932 – 9/7/1960,” Folder, “Minutes 11/25/1941–6/22/1943,” Box 1. Files R359.01.

122 “Regulations Governing the Issuance of Emergency Credentials Authorizing Public School Service in California, Plan II,” October 23, 1943. California State Archives. State Department of Education, “Division of Credentials, Commission for Teacher Preparation & Licensing Commission of Credentials, Subject Files,” Folder, “1942–1943 (1 of 2).” Files R359.04 11/2.

123 “1942 Napa City Directory,” 328, https://www.ancestrylibrary.com/interactive/2469/3143311?backurl=https%3a%2f%2fsearch.ancestrylibrary.com%2fsearch%2fdb.aspx%3fdbid%3d2469%26path%3d&ssrc=&backlabel=ReturnBrowsing#?imageId=3143489 (May 13, 2021).

124 “Gridley Notes,” Chico Record, January 10, 1918, 8.

125 Massachusetts Department of Education, Annual Report of the Division of Immigration and Americanization for the Year Ending November 30, 1939 (Boston: Wright & Potter Print. Co., State Printers, 1940), 12.

126 Kelly, “Wavering Course,” 729–33.