Oyama v. California  Oyama v. State of California, 332 U.S. 633 (1948), was a case in which the United States Supreme Court decided that specific provisions of the 1913 and 1920 California Alien Land Laws abridged the rights and privileges guaranteed by the Fourteenth Amendment to Fred Oyama, a US citizen in whose name his father, a Japanese citizen, had purchased land. In doing so, however, the court did not overturn the California Alien Land Laws as unconstitutional. The case of "Oyama v. California" developed from the 1913 and 1920 Alien Land Laws passed in California. In accordance with those laws, persons ineligible to become citizens of the United States were prohibited from owning land. Land control laws have been used in 19th century United States and can, in fact, be traced back to English common law. The California Alien Land Law of 1913 did not employ any specific language targeting Japanese residents in America, but they were the primary target. This was in part to appease the nervous California farmers, who feared that the Japanese immigrants' agricultural techniques, which developed out of the necessity to make as much use of small plots of land as possible, would render them unable to compete economically. The implicit intent of the law was not lost on the Japanese; many Japanese-American residents and even the Japanese government voiced their opposition. Japanese residents living in America sought various ways to circumvent the alien land laws. A commonly-used way to get around it was to purchase land in the name of their US-born children (who, by birth, were automatically granted American citizenship) and then to become the guardian of the property. That enabled Japanese parents to become "de facto", if not "de jure", managers and owners of land. In response to those tactics, the 1920 version of the California Alien Land Law included more stringent rules designed to end such circumvention. Among other changes, it introduced a provision that would prove to be crucial in the "Oyama" case by stating that if a person purchased land in another person’s name, it would be presumed that to have been done with the intent to bypass the Alien Land Law. That was a significant shift in the rules regarding burden of proof in state escheat cases involving land. The state used to be required to prove its case, the defendant now had to prove that the purchased land was a bona fide gift, rather than an attempt at getting around the land ownership restrictions. Another, even more stringent, provision introduced in the 1920 law prohibited assigning persons ineligible for naturalization as guardians of estate.