In Oyama et al. v. California, the U.S Supreme Court ruled in 1948 that a Californian law prohibiting non-citizens from owning land was unconstitutional. The case involved Fred Oyama, an American citizen of Japanese descent whose father had purchased land in his name while he was still a minor to circumvent the Alien Land Law of 1913 which prohibited immigrants ineligible for citizenship (including those from Asia) from owning property. When Fred became an adult and tried to claim ownership, the state attempted to seize it arguing that it had been illegally acquired by his father on his behalf as a front or "strawman". The court found this violated both Fred's rights as a citizen and also due process under the Fourteenth Amendment because it presumed guilt without evidence or trial based on race alone.

In the dissenting opinion for Oyama et al. v. California, Justice Stanley Reed argued that the majority's decision to strike down California's Alien Land Law was incorrect because it overstepped judicial boundaries by invalidating a state law without clear constitutional violation. He contended that while he did not support discriminatory laws, this particular case involved property rights and inheritance issues rather than racial discrimination against Japanese immigrants as claimed by the majority. The law in question prohibited non-citizens from owning land but allowed their citizen children to do so; thus, Kajiro Oyama’s son Fred could legally own land even though his father couldn't due to his immigrant status. Justice Reed believed that this arrangement did not infringe upon any constitutional rights of either party and therefore should have been upheld.