Courts replaced ‘Caucasian’ with European descent as the Whiteness test.

Evidence

As the court in Ex parte Shahid in 1913 stated, “The meaning of free white persons is to be such as would naturally have been given to it when used in the first naturalization act of 1790. Under such interpretation it would mean by the term ‘free white persons’ all persons belonging to the European races, then commonly counted as white, and their descendants. It would not mean a ‘Caucasian’ race.” The court found that the mixing of European, Arabian Mahometan, Mongolian, and Turkish blood barred Syrians from qualifying as “free white persons” under the naturalization statutes. European habitancy and descent became some courts’ primary standard for determining the litigant’s White racial status. Christian identity certainly worked in favor of litigants, but as Shahid demonstrates, it was not dispositive. — Sahar F. Aziz, The Racial Muslim, 544

Categorization

• XREF: This case-law Whiteness test (Europeanness over race science) is a factual anchor for the reader’s statutory-interpretation thread. — connects to: Early-1900s courts rejected European-descent limits on whiteness but conceded their legal basis — Sahar F. Aziz, The Racial Muslim: When Racism Quashes…, 1435
• DEFINE: Shows how the operative definitional category shifted from anthropological race to continental origin.