During the naturalization era, immigrants seeking citizenship were bound by the prerequisite of being found to be “free white persons” by a civil court. However, what defined whiteness was not allowed to extend beyond Christianity, and especially Protestantism, and Islam stood as its rival and thus was considered irreconcilable with whiteness. Therefore, up until 1944, Muslim identity precluded one from being deemed white by law and therefore eligible for citizenship. Furthermore, the Naturalization Act of 1790 also curbed the migration of Muslims to the United States, as they were largely aware of the opposition their religious identity would spur at ports of entry like Ellis Island.

QUESTION: Which court cases or rulings in 1944 first allowed Muslim naturalization? Worth tracing the legal history.

Khaled A. Beydoun, American Islamophobia_ Unde…, loc. 150