Foundations of Exclusion: A Timeline of AANHPI Immigration in the Late 18th-20th Centuries

Various tweaks to the Naturalization Act would be made over the following decades, but the most notable revision came in 1870, where the wording for the racial eligibility criteria was modified to “aliens being free white persons, and to aliens of African nativity and to persons of African descent." This change was not drastic by any means, but the ambiguity of the term “white” led to a flurry of cases at the appellate level by “aliens” from countries like Syria, Afghanistan, Turkey, and India. The legal ambiguity over what "whiteness" actually meant allowed immigrants from many countries, including those from South Asia, to come to America and petition the United States government to claim whiteness for themselves.

In 1870, the population of documented residents of Indian origin was 586, with this number more than tripling to 1,707 by the 1880s. Many of these immigrants argued they were white purely by their physical skin color — favoring lighter-skinned and upper-caste individuals — and ancestral connections. A hyperfixation over this specific criterion of color led to far-fetched and “ethnologically based” theories about the nature of one’s race. Opposition to these cases cited the necessity for decisions to be rooted in social grounding rather than science, and called for the “common understanding” of the “average man on the street” to determine what being “white” meant.

Caste and Whiteness

Caste often framed why, and in what manner, South Asian migrants came to the United States. Caste is an internal system of oppression and stratification in the subcontinent, and whose tendrils exist today in all of the places the South Asian diaspora lives today (Yengde, 2025). Caste shaped structures like indenture and the Coolie Trade, which impacted which laborers were on British ships coming to the UK and US. Beginning around the 1880s, Muslim ship workers would jump ship from British ships in the New York harbor, and found jobs as peddlers selling “Oriental goods,” including cotton and silk, perfumes, and rugs, to middle-class American consumers. Many of these laborers were of different caste backgrounds. Some believed their caste status would be washed away by the “Kala pani,” or black waters that took them away from the subcontinent. Others found ways to maintain caste status even in the West (Bahudar, year).

There were also immigrants, often upper caste, who came to the United States for the express purpose of education and career advancement. One such example was Anandibai Joshi, a Brahmin Marathi woman from Bombay who was the first Indian woman to receive a degree in medicine in the United States. Joshi expressed her interest in studying medicine in a letter that ended up in the hands of a Presbyterian minister stationed in India. The letter was reprinted in a Presbyterian magazine and was there read by a New Jersey woman named Theodocia Carpenter, who wrote to Joshi and ultimately sponsored her stay in Philadelphia. She was admitted into the Woman's Medical College of Pennsylvania at the age of 19 and graduated at 21, much to the admiration of advocates of women's education who had followed her journey. Though Joshi tragically died at the young age of 22 after contracting a persistent case of tuberculosis in the United States, she is regarded as a proto-feminist icon for her efforts to break both racist and sexist barriers in higher education.

You can read about more examples of South Asian immigration to the United States to participate in higher education in fellow LHP Youth Researcher Ravi's exhibit, found here.

By 1900, just over 2000 South Asian “Indians” were documented residents of the United States, although there may have been more. 408 of these initial South Asian Americans resided in New York, laying the foundation for the diverse New York South Asian population present today in areas like Queens. Some lived in segregated urban centers like Chicago and Detroit, while the West Coast's agricultural workforce offered opportunities for others. However, citizenship and the full realization of the “American Dream” were unobtainable to many of these South Asian immigrants. These early South Asian Americans defined the foundational steps into an era of significant change in immigration and naturalization policies throughout the 20th century, particularly involving South Asian immigrants. Ultimately, it is their initial strides that exist as the pillars of the modern South Asian American identity and status in the United States.

The "Hindoo" Invasion

The sudden uptick in South Asian immigrants within the United States coincided with broader resentment toward Asian immigrants as a whole. The nativist movement of this century saw immigrants from India in a similar light to those from China and, to a lesser extent, Japan: a group of people who look different than WASPs (White Anglo-Saxon Protestants) with an unfamiliar culture who worked back-breaking jobs for menial pay. Such immigrants were believed to be spreading immorality and disease and taking away jobs that should be reserved for White Americans. Numerous anti-Indian riots across the country manifested from these sentiments, with nativists coining South Asian immigration to the United States as a “Hindoo invasion."

One of the best known race riots organized specifically against South Asians took place in Bellingham, Washington, just after Labor Day in 1907. A relatively sizable South Asian population had grown in the area as a result of expanded railroad access within the Pacific Northwest and available contract work in Bellingham’s lumber mills, much to the displeasure of many white workers. A similar race riot — against Chinese migrant workers in the fishing industry — had taken place in Bellingham some years prior, and in the ensuing years, a large chapter of the Japanese-Korean Exclusion League had taken root. Explicitly organized to defend the West Coast “against Oriental invasion,” the Japanese-Korean Exclusion League’s chapter in Bellingham boasted over 800 members. Utilizing racist, fearmongering stories of immigrants stealing white jobs and committing violence against white women — tropes that have been invoked time and time again, regardless of the time period — white rioters roamed the streets of Bellingham with the goal of ridding the town of its entire South Asian population. Observing indiscriminate beatings, arson, destruction of private property, and other tactics of intimidation, Bellingham citizens and police officers did little to nothing to protect their South Asian neighbors. 

After the riots ended, their secondary utility became clear. Press accounts and written accounts of the white workers’ testimonials demonstrate that the riots were used to stress the dangerous, unassimilable nature of these “foreign” workers. In many cases, the victims of the riots were blamed for the violence itself, or at least for introducing such chaos into a “peaceful” town. The rioters’ intentions, in protecting the white supremacist foundations of their town and its economy, went largely unquestioned. Within 10 days of the riot, every South Asian resident of Bellingham would leave town, moving on to other seasonal or migratory work in the Pacific Northwest and hoping for a safer environment to call home. The Japanese-Korean Exclusion League would eventually become the Asiatic Exclusion League, bundling in the newest target of its xenophobia under a more expansive umbrella. And such organized outbursts of explicitly anti-South Asian racism would become more common as the early 20th century progressed onward.

The race riots that took place on the West Coast are one example of how white civilians chose to police race and citizenship on a social level, through organized campaigns of fear and violence. On a parallel level, challenges over race and who “counted” as a citizen were also being waged on a different stage: in court.

As the numbers of South Asians attempting to immigrate and become naturalized citizens increased in the early 20th century, the ambiguous racial legal standards that had been developed to exclude large swaths of non-white immigrants became one arena in which to challenge the existing order. Among the first South Asians to succeed in this battle was a man named Bhicaji Balsara, a Parsi Zoroastrian from Bombay who fought and won a battle in court over his status as a “free white person.” Balsara arrived in the United States around 1900 as a cotton buyer for the Tata Group and settled in New York. He petitioned for citizenship in 1906, and his case was heard before the District Court in the Southern District of New York.

Objections to Balsara’s admittance as a citizen lay largely upon the “free white persons” standard in the Naturalization Act of 1870, but Balsara’s argument was that his “color [was] white and his complexion dark.” He argued that his Parsi ancestry was an indication that he belonged to an “Aryan” race, as Parsis hailed originally from Iran. In the Circuit Court’s ruling, however, serious concerns were raised over accepting “white persons” as a broader category, including Aryan, Caucasian, and Indo-European groups, which, at the time, were seen as distinct from categories of white people in the United States and Europe. At this time, Eastern Europeans, Italians, and Irish had also not “become white,” both on social and legal levels, in the American context. To expand the acceptance to all white persons, the Court stated, "will bring in not only the Parsees… which is perhaps the purest Aryan type, but also Afghans, Hindus, Arabs and Berbers.” Newspaper coverage at the time publicly mused their fears that a precedent set in Balsara's favor would create a "loophole for little brown men and big brown men." At the same time, the Court identified Balsara’s “high character” and “exceptional intelligence,” stating that a higher court must examine this issue.

As this debate took place, the Department of Justice released a 145-page brief explaining why Parsis would not be considered as “free white persons.” Their brief cited multiple first-hand accounts of Western travellers in Persia and India describing the inhabitants as “swarthy of complexion,” and argued broadly that the Naturalization Act’s racial standard was intended to only include Europeans and people of European descent. The Circuit Court of Appeals eventually heard Balsara’s case in 1910, and ultimately ruled against the argument laid out in the DoJ’s brief. Their ruling ultimately stated that Parsis were not to be mixed up with other Indians, singling out “Hindus” as the “swarthy” population. Parsis, on the other hand, could be considered as white and as constituting a community “as distinct from the Hindus as are the English who dwell in India.” Many interested parties watched as this ruling came down, including New York's Syrian-American community, who hoped that a positive ruling in Balsara's case could help establish a precedent to be used in their own naturalization cases. 

Indeed, United States v. Balsara did have a profound legal impact on the question of South Asian naturalization in the 20th century. The Court’s decision left myriad other ethno-religious communities in South Asia — Hindus, Muslims, Sikhs, Jains, Christians, and Jews — in a legal gray area. Were they to be accepted only if they could demonstrate ancestry from a “white race”? What was even more confusing was that the decision over the status of Parsis was not definite. Twenty years after the Balsara decision, the same New York Circuit Court rejected the petition of another Parsi man from Bombay, Rustom Dadabhoy Wadia, who came to the United States in 1923 and lived on New York’s Lower East Side with his American wife, Gladys Voorhees. In their ruling, the Court insisted that the “common understanding” of “white person” be applied in such cases as Wadia’s, thus establishing that a common-sense interpretation of whiteness would exclude any South Asian heritage. This, combined with severely tightened national immigration quotas, created barriers toward naturalization that would require years of struggle to undo.

By far the most noteworthy case to come out of the South Asian legal struggle for citizenship was Bhagat Singh Thind v. United States. This case articulated clearly the way in which whiteness, caste, and immigration were interlaced systems in the United States (Shankar, 2023).

Bhagat Singh Thind was born in 1892 in Punjab, India, then a part of the British Raj. In 1913, he immigrated to the United States, settling in Seattle to pursue graduate studies. Thind was one of approximately 7,000 Indian men, many of them Punjabi Sikhs, who came to the Pacific Northwest around that time seeking economic and educational opportunities while fleeing unrest and British colonial repression in India. Thind worked summers at lumber mills in Oregon while also studying religion and literature at the University of California, Berkeley, He became involved with the Ghadar Party, an Indian independence movement organizing immigrants in North America to overthrow British colonial rule in India. When the U.S. entered World War I in 1917, Thind enlisted in the U.S. Army, becoming the first turbaned Sikh soldier in the American military. During his military service, Thind applied for U.S. citizenship. Under the 14th Amendment, all freed Black persons could become citizens. While there was no language in the amendment that specified that citizenship could only apply to white or Black people,  this is how the courts had thus far come to understand the law. Therefore, Thind’s initial petition for citizenship was initially approved but quickly overturned after opposition from the Bureau of Naturalization. In 1920, Thind applied again for citizenship in Oregon. The judge granted it based on arguments that Indians could be considered "Caucasian" and thus "white," as well as in recognition of Thind's military service. However, the Bureau of Naturalization appealed this decision to the U.S. Supreme Court.

The two questions that faced the Supreme Court were as follows: “Is a high-caste Hindu, of full Indian blood, born at Amritsar, Punjab, India, a white person within the meaning of § 2169, Revised Statutes [referring to the revised Naturalization Act]?” and “Does the Act of February 5, 1917 (39 Stat. 875, § 3) disqualify from naturalization as citizens those Hindus now barred by that act who had lawfully entered the United States prior to the passage of said act?" Thind extended the argument from his appeal in Oregon: he considered himself a “free white person” and was thus eligible for citizenship.

One of the most important precedents this argument, and overall this case, was based upon was the Ozawa v. United States case. Argued just months prior, Ozawa established that a “white person” referred to anyone of the Caucasian race as commonly understood. A “common understanding” of who belongs to what race opens up the debate to numerous interpretations of what understandings are correct and incorrect, and this was where Thind’s argument hinged. He described himself, a full-blooded Hindu from Punjab, as a “Caucasian”: "The applicant contends that the words 'white persons' are synonymous with the words 'Caucasian race, and that the Hindus are included therein." Thind relied on the caste hierarchies of the South Asian subcontinent to make his argument about whiteness. The court was not convinced. They rejected any anthropological definitions of a “high-class Hindu” being a member of the “Caucasian” or “Aryan” race. Instead, the Court’s understanding of Thind’s argument was solely based on language alone and the Ozawa “common understanding” of language. The Court seemingly confused itself, with Justice Sutherland noting that the term "Caucasian" was "a conventional word of much flexibility." At the same time, the common understanding of “Caucasian” was to be white, and Thind, to the common man, was not white.

Thus, the case of Bhagat Singh Thind is an important reflection of the shifting relationship between whiteness and citizenship in United States legal history. It is also an important lesson for South Asian folks: relying on caste and proximity to whiteness did not serve Bhagat Singh Thind well. 

Naturalization Act of 1870

Vivek Bald, Bengali Harlem and the Lost Histories of South Asian America (2013)

Neilesh Bose ed., South Asian Migrations in Global History: Labor, Law, and Wayward Lives (2020)

Rajender Kaur, "The Curious Case of Sick Keesar: Tracing the Roots of South Asian Presence in the Early Republic" (2017)

Taylor McNeil, "The Long History of Xenophobia in America" (2020)

1870: Expanded—But Not for All

Gaiutra Bahadur, Coolie Woman: The Odyssey of Indenture (2013)

Reece Jones, White Borders: The History of Race and Immigration in the United States from Chinese Exclusion to the Border Wall (2021)

Beth Lew-Williams, The Chinese Must Go: Violence, Exclusion, and the Making of the Alien in America (2018)

Nishant Upadhyay, Indians on Indian Lands: Intersections of Race, Caste, and Indigeneity (2024)

Suraj Milind Yengde, Caste, A Global Story (2025)

20th Century South Asian Migrations and NYC

Amy Bhatt and Nalini Iyer, Roots and Reflections: South Asians in the Pacific Northwest (2013)

Erika Lee, America for Americans: A History of Xenophobia in the United States (2019)

Nayan Shah, Stranger Intimacy: Contesting Race, Sexuality and the Law in the North American West (2012)

Seema Sohi, Echoes of Mutiny: Race, Surveillance, and Indian Anticolonialism in North America (2014)

A Century of Challenges

Doug Coulson, Race, Nation, and Refuge: The Rhetoric of Race in Asian American Citizenship Cases (2017)

Hardeep Dhillon, "The Making of Modern US Citizenship and Alienage" (2023)

Maia Ramnath, Haj to Utopia: How the Ghadar Movement Charted Global Radicalism (2011)

Bhagat Singh Thind v. United States

Arjun Shankar, "On Brown Blood: Race, Caste, and the Bhagat Singh Thind Case" (2023)

Ian Haney Lopez, White by Law: The Legal Construction of Race (2006)