Mangesh Duggal


In 1890, Hong Yen Chang brought a motion before the California Supreme Court to seek admission to the California Bar. In denying Chang’s application, the California Supreme Court ruled in part “a certificate of naturalization issued to a Chinaman is void.” About one hundred and twenty-five years later, Chang’s descendants and the Asian Pacific American Law Students Association at the University of California, Davis School of Law brought a motion before the Supreme Court of California to posthumously admit Hong Yen Chang to the California Bar. On March 16, 2015, a unanimous seven-member panel of the California Supreme Court granted the motion posthumously admitting Chang as an attorney and counselor in California. This case comment analyzes the California Supreme Court’s decision and consists of three parts. Part I explores Chang’s extraordinary upbringing and outlines the underlying historical and legal backdrop of his legal education. Part I also includes a description and analysis of the 1890 rejection by the California Supreme Court, hereafter known as Chang I. Part II analyzes the posthumous admission by the California Supreme Court in 2015, i.e. Chang II. Part III sets out the legal framework for the Court’s decision and what guidance the decision provides going forward.



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