Talk:Chae Chan Ping v. United States/GA1

GA review

The following discussion is closed. Please do not modify it. Subsequent comments should be made on the appropriate discussion page. No further edits should be made to this discussion.

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Nominator: Irruptive Creditor (talk · contribs) 03:41, 26 May 2025 (UTC)

Reviewer: ViridianPenguin (talk · contribs) 03:06, 9 July 2025 (UTC)

@ViridianPenguin, to address point 4, I've redone it as: "The Angell Treaty of 1880 was later negotiated to limit Chinese immigration to the United States.". Pleasant editing, Irruptive Creditor (talk) 15:29, 9 July 2025 (UTC)

@ViridianPenguin, I reformatted the portion relating to United States ex rel. Knauff v. Shaughnessy, 338 U.S. 537 (1950), to "First, the Supreme Court held in United States ex rel. Knauff v. Shaughnessy (1950) that immigration was a privilege and reaffirmed Nishimura Ekiu, stating: [blockquote]." Pleasant editing, Irruptive Creditor (talk) 10:10, 18 July 2025 (UTC)

@ViridianPenguin, quote relating to Przybyszewski (source 21) was not a fabricated quote, but a mismatch. That quote comes from the one which precedes it (source 20), "A Nineteenth Century Habeas Corpus Mill: The Chinese before the Federal Courts in California", by Christian Fritz, which states in the pertinent part on page 370:

While the affirmation of Sawyer's decision ended any challenge to the Act itself, it did not mark, as many thought, an effective end to Chinese immigration and the use of the federal courts by the Chinese to establish their right of entry. The anti-Chinese movement might have observed that Sawyer went out of his way to explain that the decision he and Hoffman reached did not represent a capitulation to popular prejudice."

The source by Przyszewski, "Judge Lorenzo Sawyer and the Chinese: Civil Rights Decisions in the Ninth Circuit", (source 21) is to support the claim that Judge Sawyer showed sympathy towards Chinese immigrants, with the source stating on the very first page that:

From his earliest letters back describing the gold camps, through his term on the California Supreme Court, to his lengthy and final position as circuit judge of the Circuit Court for the Ninth Circuit, Sawyer displayed a rare sympathy for Chinese immigrants.

I have thus re-arranged the sources accordingly. As for the rest, I have check them and the direct quotes are accurate insofar as I have reviewed. Pleasant editing, Irruptive Creditor (talk) 21:43, 19 July 2025 (UTC)

GA review – see WP:WIAGA for criteria

1. Is it well written?

   A. The prose is clear and concise, and the spelling and grammar are correct:

   "While Chae Chan Ping has been criticized for its discriminatory outcome, judicial deference to immigration and nationality law has continued into the 21st century." The correct preposition would be "judicial deference in immigration and nationality law" because the intent is to describe deference in a field, rather than saying judges defer to the law. The latter meaning would be confusing because judges set the common law of immigration.  Done

   B. It complies with the manual of style guidelines for lead sections, layout, words to watch, fiction, and list incorporation:

2. Is it verifiable with no original research, as shown by a source spot-check?

   A. It contains a list of all references (sources of information), presented in accordance with the layout style guideline:

   B. Reliable sources are cited inline. All content that could reasonably be challenged, except for plot summaries and that which summarizes cited content elsewhere in the article, must be cited no later than the end of the paragraph (or line if the content is not in prose):

   C. It contains no original research:

   "First, the Supreme Court held in United States ex rel. Knauff v. Shaughnessy (1950) that immigration was a privilege, and reaffirmed Chae Chan Ping and Nishimura Ekiu, stating: [blockquote]." Since "affirm" has a legal meaning of explicitly confirming a case's continued validity, while Knauff never cites Chae Chan Ping but relies on Nishimura Ekiu for the following blockquote, this should be reformatted to "First, the Supreme Court held in United States ex rel. Knauff v. Shaughnessy (1950) that immigration was a privilege and reaffirmed Nishimura Ekiu, stating: [blockquote]."  Done

   I performed a spot check of five sources: Source 6 (Santa Clara University digital exhibit) is accurately used to quantify Chinese migration during the California gold rush. Source 13 (Long et al. 2024) is misquoted, which I have fixed. Source 15 (Lu 2010) is accurately used for explaining early enforcement of the Chinese Exclusion Act. Source 31 (Shoukfeh 2023) is accurately cited for claims and a quote from Field. Source 41 (Chacón 2007) is accurately used to explain Wong Wing v. United States.

   As the Source 13 misquote was introduced by the nominator, I proceeded with a spot check of three more sources: Source 21 (Przybyszewski 1988; accessible via HeinOnline through WP:TWL) is cited following a quote about Judge Lorenzo Sawyer that does not appear in her paper. Once again, this misquote of the source came from the nominator. Source 33 (Stuebner 2024) supports the claim of judicial deference in immigration law having Roman origins and approval from Gouverneur Morris. Source 37 (Wilson 2019) includes the associated quote from Nishimura Ekiu v. United States. @Irruptive Creditor: I will leave the reworking of Source 21 to you. Ping me once you have re-confirmed that all sources support their associated statements with special focus on direct quotes.

   Thanks for clarifying the quote's source. I proceeded with a spot check of a further three sources: Source 26 (Martin 2015) supports the conflict of laws claim. Source 35 (Coutin et al. 2014) supports the plenary power doctrine explanation. Source 54 (EBSCO explainer of Boutilier v. Immigration and Naturalization Service) supports this article's explanation of that case.

   D. It contains no copyright violations nor plagiarism:

3. Is it broad in its coverage?

   A. It addresses the main aspects of the topic:

   B. It stays focused on the topic without going into unnecessary detail (see summary style):

   Compared to the article's state when you started working on it in Feb 2025, great job adding century-by-century subsequent developments without getting bogged down in unnecessary detail!

4. Is it neutral?

   It represents viewpoints fairly and without editorial bias, giving due weight to each:

   "The Burlingame Treaty was ultimately unsuccessful, and the Angell Treaty of 1880 was later negotiated to limit Chinese immigration to the United States." By whose judgement and which metric was the Burlingame Treaty "unsuccessful"? A slight expansion on how Congress came to resent and then restrict Chinese laborers would be helpful here.  Done

   Given that you already have two relevant sources for that sentence, an expansion rather than contraction is preferable. I have rewritten it to "In response to racial hostility, the Angell Treaty of 1880 was later negotiated to limit Chinese immigration to the United States."

5. Is it stable?

   It does not change significantly from day to day because of an ongoing edit war or content dispute:

6. Is it illustrated, if possible, by images?

   A. Images are tagged with their copyright status, and valid non-free use rationales are provided for non-free content:

   B. Images are relevant to the topic, and have suitable captions:

   I removed all the periods in sentence fragment image captions per MOS:CAPFRAG.

7. Overall: Wonderful job expanding this article!

   Pass or Fail:

The discussion above is closed. Please do not modify it. Subsequent comments should be made on the appropriate discussion page. No further edits should be made to this discussion.