Hong Yen Chang


Hong Yen Chang was reportedly the first Chinese immigrant licensed to practice law in the United States. Though admitted to the New York State Bar, he was denied admission to the California State Bar in 1890. He remained a prominent member of the Chinese community and went on to lead a distinguished career in banking and diplomacy.

Early life

Chang was born in 1860, in what is now Xiangshan, Guandgong Province, China. Chang's father died when he was 10 years old.

Chinese Educational Mission

In 1872, Chang was selected to travel to the United States as part of the Chinese Educational Mission. He arrived in the United States at thirteen years old and lived with American families. Chang attended Hartford Public High School in Connecticut from 1876 to 1878. Beginning in 1878, Chang studied in a college preparatory program at the Phillips Academy in Andover, Massachusetts. Chang graduated from the Phillips Academy in 1879, giving an English oration at his commencement ceremony titled "The Influence of Greece beyond Greece."
In 1879, Chang began studies at Yale College. In 1881, however, the Chinese government recalled the Chinese Educational Mission students back to China.

Legal Studies and Legal Career

Hong Yen Chang did not remain in China for long, though. He returned to the United States on his own accord and began studies at Columbia Law School in 1883. He graduated with honors from Columbia Law School in 1886. He received "high markings from the examiners" and had unanimous recommendation for bar admission.
At the time of Hong Yen Chang's graduation, the New York State Bar required applicants to be United States citizens. But the Chinese Exclusion Act barred Hong Yen Chang from citizenship. The New York Supreme Court, General Term, initially opposed Hong Yen Chang's admission to the New York State Bar. However, the New York State Legislature passed an act that allowed Hong Yen Chang to apply again to the bar. The act, "An Act for the relief of Hong Yen Chang," reads:
The New York Supreme Court, General Term admitted Chang to the New York State Bar on May 17, 1888. The New York Times hailed him as the first admitted Chinese lawyer in the United States.

''In re Hong Yen Chang''

Soon after Chang's admission to the New York State Bar, Chang moved West to California and sought admission to the California State Bar. His motion to practice law in California reached the California Supreme Court in 1890. Under the California Code of Civil Procedure at the time, "Every citizen of the United States... who has been admitted to practice law in the highest court of a sister state... may be admitted to practice in the courts of this State upon the production of his license and satisfactory evidence of good character; but the court may examine the applicant as to his character." In support of his eligibility to practice law in California, Chang submitted his license to practice law in New York and "a certificate of naturalization, issued by the court of common pleas of the city of New York, November 11, 1887." The state Supreme Court denied his motion to practice law in California, finding the naturalization certificate issued by New York invalid under the Chinese Exclusion Act. The court held:
In 2011 members of the U.C. Davis Asian Pacific American Law Students Association, with the assistance and supervision of Prof. Gabriel Chin, petitioned the Supreme Court of California to grant Chang posthumous admission to the State Bar of California. On March 16, 2015 the Court granted that petition.

Later life

Chang married Charlotte Ah Tye on March 14, 1897, in San Francisco.
Between 1888 and 1895, Chang worked for the Chinese Consulate in San Francisco as an advisor. He then worked for the Yokohama Specie Bank of Japan in San Francisco.
In 1907, Chang left San Francisco and returned to China. Chang became the Accountant-General to the Treasury's Shanghai branch. Around the same time, he was appointed to a chair at Nanjing Government University to teach international law and banking.
In 1908, Chang became a diplomat, participating first in a Special Mission to the United States, and then serving the Chinese Legation in Washington, D.C. Between 1910 and 1913, he served as the Chinese Consul in Vancouver, British Columbia. The Chinese government awarded him a doctorate of law for his services. Hong Yen Chang held other prestigious positions, including Director of Chinese naval students at Berkeley, California, until his retirement in 1920.
Chang died on August 4, 1926, in Berkeley, California.