The U.S. Supreme Court case Takuji Yamashita et al. v. Hinkle, Secretary of State of the State of Washington in 1922 revolved around a law that prohibited non-citizens from owning land in Washington state. The plaintiffs were Japanese immigrants who had lived and worked in the United States for many years but could not become citizens due to federal laws barring Asian immigrants from naturalization at that time. They challenged this law on grounds that it violated their rights under the Fourteenth Amendment's Equal Protection Clause and was discriminatory based on race or nationality. However, the Supreme Court upheld the constitutionality of Washington’s Alien Land Law by ruling against Yamashita and his co-plaintiffs with an unanimous decision stating that states have broad power over property within their borders, including deciding who can own land; thus they did not find any violation towards Fourteenth Amendment's Equal Protection Clause as claimed by plaintiffs. This verdict further solidified anti-immigrant sentiments during this period which led to more restrictive immigration policies targeting Asians until changes were made post World War II.

In the dissenting opinion for Takuji Yamashita et al. v. Hinkle, Justice Oliver Wendell Holmes argued that the majority's decision to uphold Washington State's law barring non-citizens from owning land was based on a misinterpretation of the Fourteenth Amendment. He contended that while states have broad powers to regulate property rights, these powers do not extend to outright discrimination against individuals based on their nationality or race. Furthermore, he suggested that such discriminatory laws undermine America’s commitment to equality and justice by creating an unjust hierarchy of citizenship rights. Holmes also criticized the majority for failing to consider international implications of their ruling; specifically how it might affect U.S.-Japan relations at a time when tensions were already high between two nations.