Bureaucratic Tyranny THE BUREAU OF IMMIGRATION AND ITS CRITICS
Given the outcome in Ju Toy, it is not surprising that Commissioner General of Immigration Frank P. Sargent expressed great satisfaction in his annual report for 1905 with the agency's administration of Chinese exclusion. "In no [other] branch of its widespread activities," crowed Sargent, has the bureau "so thoroughly succeeded in carrying into effective operation the purpose of the laws." Yet he devoted the remainder of his report on Chinese exclusion to defending the bureau against severe criticisms mounted by "a large and somewhat vociferous element" who opposed the policy and denounced officials responsible for its enforcement. 1 Indeed, the bureau had only a few days to enjoy its victory in Ju Toy before Chinese launched a dramatic boycott of American goods, largely in protest against the Bureau of Immigration's treatment of them. Any hope that the bureau had that Ju Toy would end the struggle over Chinese exclusion was soon dashed by the boycott.
Ironically, the agency's success in the litigation leading up to Ju Toy provided the very impetus for new, broad-based challenges to its authority. The bureau had emerged in 1905 as an agency with unusual power over both aliens and alleged citizens. In the words of one critic, the Supreme Court had "emancipated" the Bureau of Immigration from the federal courts and, in its sanctioning of summary administrative methods, had loosened the hold of constitutional and judicial norms. Immediately preceding Ju Toy, well-publicized cases involving both Chinese and non-Chinese immigrants had generated concern about the possible abuses of ad