This Teaching Guide is part of a series. Each of the four total teaching guides speaks to one aspect of the history of free speech. Although they work together to tell different parts of this history, it is not necessary to teach all of the guides or to teach them in a certain order. Each guide is a self-contained lesson.
(A PDF version of this teaching guide is also available for download-see left) 

Other guides in the series:
Free Speech Teaching Guide 1: The Birth of the Modern First Amendment: How Oliver Wendell Holmes Changed His Mind
Free Speech Teaching Guide 2: Brandenburg v. Ohio (1969): Defining and Arguing Hate Speech 
Free Speech Teaching Guide 3: The Problem of National Security Secrets

"Male Immigrants at Ellis Island," Library of Congress

Recommended for:

• 11th Grade US History
• 12th Grade US History
• Undergraduate History

Table of Contents

Guide Introduction:
This introduction briefly previews the topics included in this guide that spans the twentieth century and ends with a 1972 Supreme Court Case.

Classroom Activities
Exercise 1: "The unrestricted dumping-ground" (1903). A guided analysis of a 1903 political cartoon with annotations and questions. Why was immigration a heated debate in the early twentieth century?
Exercise 2: Who gets a Visa? A close reading of an excerpted 1984 article with guiding questions, notes, and class discussion options. Why deny visas?
Optional Exercise: Visa Waivers. Ask students to consider the more complicated reality of the visa law. How did waivers work and did they undermine political exclusion?

Framing Essay
Scholarly Context: How do visa laws and the First Amendment connect? An introduction to the Mandel Supreme Court case.
Annotated Decision: Notes on the Mandel SCOTUS decision for context or to help guide a close reading.
Key Takeaways: Concluding connections between immigration law and free speech law and prompts for class discussion.

Guide Introduction

        Throughout the 20th century, the U.S. government has denied visas to individuals because of their politics: anarchists in the early 20th century, communists in the Cold War, those it deemed advocates of terrorism in the 1990s and early 2000s. In the first half of 2025, the Second Trump Administration began seeking to deny visas to students and others engaged in pro-Palestinian advocacy during the war in Gaza.
        To be denied a visa means either that you can’t enter the country, or that you can be deported. Governments claim that this use of the visa regulations is simply a part of their control over immigration policy – they have a right to determine who can enter the country. Critics and civil liberties activists argue that it is a form of censorship, one that should be barred by the First Amendment. The relationship between visa laws and free speech was most closely examined in a 1972 case Mandel v. Kleindeinst. The case is also significant because it focused on a neglected aspect of the right to free speech – not the rights of the speakers to say what they want, but the rights of listeners and audiences to hear what they want.
        This guide traces the history of ideological visa denial to explore the intersection between immigration law and the right to free speech. It includes:

1.  An overview of the history of visa denial in early 20th century, which allows students to assess historical fears of radical immigrants through the close reading of a political cartoon.
2. A discussion of the denial of visas to communists and alleged radicals in the Cold War, through a classroom exercise and discussion of an excerpted newspaper article.
3. An assessment of the role of the First Amendment in challenging visa restrictions through a close reading of a Supreme Court decision in 1972.

Classroom Exercise I: "the unrestricted dumping-ground" (1903)

Contents:
Overview
Annotated Cartoon
Questions for Students & Extended Context

Overview:
       The first efforts to exclude radicals from the United States came in 1903, when Congress passed a law barring anarchists from entering the country. This was a response to the assassination of President McKinley in 1901, which played into widespread anxieties that radical ideologies and crime were being brought to the country by immigrants. This 1903 cartoon captures the mood. The following pages include my annotations, as well as questions I use.

1. Have students examine the cartoon individually or in groups.
2. Invite students to share what they notice and ask more specific questions to guide conversation. This should mimic a close reading.

For the Printable Image See: linked source

Image Source Here

Annotations:

• McKinley assassination
  • McKinley (or McKinley’s ghost) is depicted in the top-left.
  • Leon Czolgosz, the gunman, was born in Detroit, but was the child of immigrants.
  • The cartoon, however, suggests the threat of anarchism is coming from immigrants, a widespread assumption at the time. “There is no such thing as an American anarchist,” said one newspaper column.
• Both the container label “direct from the slums of Europe daily” and the title of the cartoon advocate for immigration restriction.
• Depiction of Immigrants
  • McKinley and Uncle Sam are depicted as white, compared to the darker-skinned immigrants. At the time, most concern was about immigration from the south and east of Europe – groups that would later be considered white, but which were then treated as distinct races.
  • Immigrants are drawn to be animalistic, communicating an idea that they were less human and more threatening than white Americans.
• Politics & crime:
  • Three migrants at the bottom are labeled “socialist,” “anarchist,” and “mafia,” associating socialists and anarchists with crime. The socialist carries a gun labelled “murder;” the anarchist a knife labelled “assassination,” further associating these political ideologies with violence.
  • There were radical leftists committed to political violence at the time. One wing of the anarchist movement, for instance, engaged in what it called “propaganda by the deed” – symbolic acts of political violence. Between 1880 and 1910, anarchists assassinated heads of state in Austria, Italy, Greece, France, Spain, Russia (twice), and Portugal – as well as McKinley in the U.S.
  • While many radical leftists rejected political violence, this cartoon suggests they were all criminals.

By the early Cold War, the bar on anarchists entering the country remained, and had been expanded to include Communists and advocates of communist revolution. The visa had also become a more powerful bureaucratic instrument. During World War I, for the first time the U.S. began requiring all visitors to the U.S. to receive a visa, which allowed a new degree of oversight and examination of applicants. A new Visa Division was created in the State Department to do this work.

Questions for Students:

1. How are immigrants depicted?
2. What is this cartoon arguing?
3. Would immigration restriction be a useful remedy to the problems revealed by McKinley’s Assassination? What would have to be true for it to be effective for this purpose? What other remedies might be available?

Classroom Exercise II: Who gets a Visa?

Contents:
Overview
Excerpted Newspaper Article
Guiding Questions, Notes, & Class Discussion

Overview:
       A close reading of a later news article brings the topic of immigration and citizenship closer to the modern day for students. This exercise is centered around an excerpted 1984 newspaper article that discusses some individuals who were denied visas as well as efforts to reform the law. The article, like the cartoon in exercise 1, thus reveals some of the political dynamics involved.
        The next page includes some reading questions (as well as additional notes I might add), followed by a question for in-class discussion.

Excerpted Newspaper Article:
Kristin Helmore, “Would William Shakespeare get a Visa?” Christian Science Monitor, May 30, 1984.
       WALK into any bookstore in the United States and the works of Nobel Prize-winners Gabriel Garcia Marquez of Colombia and Pablo Neruda of Chile will be easily available. Anyone who wants to can buy Mexican novelist Carlos Fuentes's works or those of Italian writers Alberto Moravia and Dario Fo. And the titles of books by English novelist Graham Greene are almost household words in this country. Yet each of these acclaimed writers, and many others as well, has on at least one occasion been denied an entry visa to visit the United States.
        The law responsible for this policy is a section of the McCarran-Walter Immigration and Nationality Act of 1952, which some people would like to change. A bill has been introduced in Congress to do just that.
        ''Section 28,'' as it is called, empowers consular officials to refuse non-immigrant visas to foreigners who are or have been members of ''communist'' or ''anarchist'' organizations, as well as those who merely ''write, publish . . . circulate, display, or distribute . . . any written or printed matter advocating or teaching opposition to all organized government.'...
       The exclusion of writers from the US on ideological grounds can take place for a number of specific reasons. According to data collected by PEN, an international association of writers with offices in 55 countries, Gabriel Garcia Marquez was denied entry to the US from 1963 to '71 because of his affiliation with the leftist news agency La Prensa. Since that time, he has been granted entry only on presentation of a formal letter inviting him to a specific event. Last month, Mr. Garcia Marquez was denied entry into the US to speak at a meeting in New York on US policies in Latin America. Finally, in late April, he was granted a multiple-entry visa for one year.
        Pablo Neruda, the late Chilean poet and diplomat, was denied entry on the basis of his membership in the Chilean Communist Party. This ruling was waived on two occasions, in 1966 and '72, as a result of petitions put forward by PEN. ...
       Since 1961, Carlos Fuentes, the Mexican author and politician (who virtually grew up in Washington where his father was Mexican ambassador), has either been denied a visa to the US or issued restricted visas, even though he has been invited on numerous occasions to make public appearances under the auspices of respected institutions. He has received an honorary degree from Harvard University and was recently a visiting scholar at Princeton University. ...
        ''It's a scandal and a hateful thing for a democracy to perpetuate this kind of exclusionary policy,'' [novelist William] Styron said. ''It allows the United States to be branded as a bigoted nation filled with hysteria about communism.'
        Both Arthur Miller and John Irving raised the specter of McCarthyism. ''I doubt strongly that this law could have been passed before 1952, the wildest time of McCarthyism . . . but it's hung on the books because most people aren't aware of it,'' Mr. Miller said.
        ''I hope it's clear that we would improve our national character by ridding ourselves of these vestiges of McCarthyism which shame us today,'' Mr. Irving said.
        Carolyn Forche remarked, ''I am puzzled as to why my government is afraid of a free exchange of ideas. I would hope that my country and its institutions are strong enough to endure freedom of expression.' ...
        Support for the existing law was recently expressed on ABC's ''Nightline'' by Roy Cohn, counsel in the early 1950s to the Senate's Permanent Investigations Subcommittee headed by the late Joseph R. McCarthy: ''This law is aimed at people who present a threat to national security. Under various circumstances they should not be let in. They have access to courts where their visa denial can be overruled.' ….
        Opposition to Section 28 of the McCarran-Walter Act has a long history. In 1952, President Harry S. Truman vetoed the act, remarking, ''Seldom has a bill exhibited the distrust evidenced here for aliens and citizens alike.'
        Congress overrode Mr. Truman's veto."

Guiding Questions, Notes & Class Discussion:

1. Who are some individuals who have been denied visas?
   1. Besides those named in the article, some famous individuals (though perhaps not famous to students today) include Charlie Chaplin, Pablo Picasso, Dorris Lessing, Nazim Hikmet, Czeslaw Milosz, C.L.R. James.
2. What law was used to deny their visas?
   1. The 1952 Immigration and Nationality Act consolidated all previous immigration laws – including the Anarchist Exclusion Act of 1903 and an Internal Security Act of 1950.
   2. It was passed over Truman’s veto – a place to discuss the veto power with students if you think appropriate.
3. Why do civil liberties groups want to reform the law?
   1. Beyond discussions of the impact of the law on the individuals involved, I make sure to draw student attention to William Styron’s argument that the law makes America look bigoted and intolerant.
4. Why does Roy Cohn say we need such a law?
   1. How does this perspective complicate or affirm students’ thoughts on this debate?

Class Discussion:

• Do students think denying visas under this law is a good or a bad thing?
• Do they agree that there are national security grounds under which someone should be denied entry to the country? Do those grounds extend to political beliefs?
  • If you have used the other Free Speech Teaching Guides that cover Schenk v. US and Brandenburg v. Ohio, this is an opportunity to discuss what "harm" the law is intended to prevent.

Optional Exercise: Visa Waivers

        The visa law had a waiver process. If you were denied a visa because you were a member of a communist party, the Attorney-General could issue a “waiver” – letting you into the country just this time.

If students are opposed to the law, you can ask them if this waiver process is enough to satisfy them?

        There was some dispute over how frequently this process was delayed, and how many waivers were granted. But many were granted waivers. However, an additional concern was that the Attorney-General could attach conditions to the waiver – saying visitors could not travel to certain areas, or engage in certain types of activities. (we will see an example of these conditions in the Mandel case).

Framing Essay

Scholarly Context:
       How did these visa laws intersect with the First Amendment? They are clearly a form of punishment for political speech. As early as 1903, an anarchist being deported under the anarchist exclusion law claimed that his First Amendment rights were being violated. The Supreme Court ruled that foreigners could not claim First Amendment rights to stay in the country. As we discussed in the guide, Schenk v. U.S. (1919): The Birth of the Modern First Amendment, this was typical of the narrow way that the Supreme Court protected First Amendment rights before the mid-twentieth century. And in 1945, in a case concerning an attempt to deport an Australian labor leader, the Supreme Court said that noncitizens in the U.S. have the same First Amendment rights as citizens. Of course, in the early 1950s, American citizens didn’t have the right to advocate for Communism, and so many communists were deported in the McCarthy period, just as many Americans citizens were jailed. Today, the standards would be different.

Find the text of the First Amendment Here

       But what about the rights of the foreigner to enter the country? Here, courts have rejected the notion that foreigners can claim a First Amendment right to come into the U.S. if the U.S. has a law that would exclude them. The Supreme Court has ruled that the right to determine who can and can’t enter the country is what it calls the “Plenary Power” – part of what it means to be a government of a nation-state is the right to choose who can enter the country, and no court can interfere with those decisions.
        That has meant that foreigners can’t claim a First Amendment right to enter the country (they can claim such a right if they are being deported after entering, though the law is complex in this area.) But in the late 1960s, a group of university professors tried a different strategy to challenge the visa laws. They had invited Ernest Mandel, a Belgian Marxist theorist, to come to their campuses to give talks and engage in debates. Mandel was denied a visa because he advocated world communism.

Note (if you discussed the waiver program earlier):
       Mandel had been given waivers to enter the country in 1962 and 1968. But in 1969 he was denied a waiver. This was because 1) in 1968 he spoke at more universities than his waiver granted, and 2) after one of these talks, students auctioned posters to send money to French protestors – which violated a condition attached to Mandel’s waiver that he not speak at events where funds were raised for political causes. Mandel had not been told that these conditions were attached to his waiver. This can be a place to return to your discussion of the waiver program, to see if these details change or reinforce students’ earlier attitudes.

Annotated Decision:
       Mandel, as a foreigner, couldn’t claim his First Amendment rights were violated by his exclusion from the country. But the university professors argued that their rights were violated by his exclusion from the country – they wanted to listen to him, to talk to him, to meet with him. A lower court agreed with them, ruling that Mandel’s exclusion violated the First Amendment. The government appealed to the Supreme Court, which ruled 6-3 that Mandel’s exclusion was constitutional. Here’s what the Supreme Court said, along with some notes I use to teach the decision:

The decision text:
"The case…comes down to the narrow issue whether the First Amendment confers upon the appellee professors, because they wish to hear, speak, and debate with Mandel in person, the ability to determine that Mandel should be permitted to enter the country or, in other words, to compel the Attorney General to allow Mandel's admission. ….
The Government also suggests that the First Amendment is inapplicable because appellees have free access to Mandel's ideas through his books and speeches, and because 'technological developments,' such as tapes or telephone hook-ups, readily supplant his physical presence. This argument overlooks what may be particular qualities inherent in sustained, face-to-face debate, discussion and questioning. While alternative means of access to Mandel's ideas might be a relevant factor were we called upon to balance First Amendment rights against governmental regulatory interests—a balance we find unnecessary here in light of the discussion that follows in Part V—we are loath to hold on this record that existence of other alternatives extinguishes altogether any constitutional interest on the part of the appellees in this particular form of access."
Recognition that First Amendment rights are implicated, however, is not dispositive of our inquiry here. In accord with ancient principles of the international law of nation-states, the Court in The Chinese Exclusion Case 1889, and in Fong Yue Ting v. United States (1893), held broadly…that the power to exclude aliens is 'inherent in sovereignty, necessary for maintaining normal international relations and defending the country against foreign encroachments and dangers—a power to be exercised exclusively by the political branches of government.' ...

In summary, plenary congressional power to make policies and rules for exclusion of aliens has long been firmly established. In the case of an alien excludable under § 212(a)(28), Congress has delegated conditional exercise of this power to the Executive. We hold that when the Executive exercises this power negatively on the basis of a facially legitimate and bona fide reason, the courts will neither look behind the exercise of that discretion, nor test it by balancing its justification against the First Amendment interests of those who seek personal communication with the applicant. What First Amendment or other grounds may be available for attacking exercise of discretion for which no justification whatsoever is advanced is a question we neither address or decide in this case.”

Annotations:

• ["This argument overlooks what may be particular qualities inherent in sustained, face-to-face debate, discussion and questioning."]
  • The Government was claiming that the professors could speak to Mandel just as easily by telephone, and so his presence was not necessary. The court is skeptical of this claim.
    • In the era of zoom, do students think there is any benefit to in-person conversation? or is online discussion good enough?
• ["Recognition that First Amendment rights are implicated..."]
  • The Supreme Court concedes here that there is a First Amendment right to hear Mandel. There are a number of other cases in the period which emphasize that the right to speak matters not for the speaker, but for the audience - that the First Amendment is important for its role in preserving a broader culture of debate and exchange.
  • Many students will think only about the rights of the speaker, so this is an important place to slow down and demonstrate how many more rights are involved.
• ["The Chinese Exclusion Case 1889, and in Fong Yue Ting v. United States (1893)..."]
  • These are important late nineteenth century cases which established the Plenary Power. Congress passed the Chinese Exclusion Act in 1882, barring Chinese entry to the country. In these legal cases, courts said that they could not overrule political decisions made by Congress as to who could enter the country.
• ["facially legitimate and bona fide reason..."]
  • This is a very deferential standard. In other first amendment cases, the Supreme Court has carefully scrutinized the government's rationale for a law, to make sure it isn't a cover for political discrimination. But here, the court says explicitly that if the government offers a justification that seems reasonable, the courts will not look any closer, or consider the First Amendment.
  • In dissent, Justice Marshall was very critical of this approach:
    • "I do not understand the source of this unusual standard. Merely 'legitimate' governmental interests cannot override constitutional rights. Moreover, the majority demands only 'facial' legitimacy and good faith, by which it means that this Court will never 'look behind' any reason the Attorney General gives. No citation is given for this kind of unprecedented deference to the Executive nor can I imagine (nor am I told) the slightest justification for such a rule."
• ["What First Amendment or other grounds may be available for attacking exercise of..."]
  • This is an ambiguous final sentence, which can be used to help students understand the difficulty in working out how much precedent a given case is setting.
  • This sentence seems to leave open the possibility that there are some instances of visa denial which would raise First Amendment concerns - those in "which no justification whatsoever is advanced." But under what circumstances would a justification fail to be "facially legitimate and bona fide"?
  • The Court has never revisited the visa denial process, so the meaning of these sentences remains unresolved.

Key Takeaways:

• Visa denial is at the crossroads of two discrete fields of the law: immigration law and free speech law.
  • In immigration law, courts have been very deferential to the power of the government to decide who can enter the country; in free speech law, courts have been very skeptical of government claims that it needs to regulate debate and discussion.

Do students think cases like Mandel’s – or more recent cases, if there have been some in the news – are better treated as First Amendment or immigration cases? Or do they think that these two areas of the law should be combined?

• This can be an interesting place to leave the class discussion – asking students both to consider their own values in this complex area, and also to show them how the answers to legal questions are often shaped by the ways that courts and lawyers sort them into different doctrinal domains.

What is it?

Immigration is a hotly contested issue that brings up strong reactions on both sides. Immigrants form communities that are integrated with communities of other immigrants and Americans who were born in the U.S. They live in cities and in rural areas and in all regions of the country. Increasingly they come from all over the world. This guide supports students as they examine sources related to immigration from Asia and look for connections and commonalities between these communities and their own.      

Key points:

• This activity will take one 90-minute period or two 45-minute periods. It is appropriate for a high school U.S. history or government classroom, but can be modified for a variety of learners.
• Students will analyze, interpret, and evaluate primary sources. 
• Students will learn more about the variety of immigrants who have made their home in the United States. 
• Guiding Question: What can we learn about photographs of immigrant communities from Asia in the U.S.?  

Introduction

Immigration is a commonly taught topic in United States history courses especially in the 19th century through the early 20th century, but there are fewer resources available on immigration from the 1960s to the present day. In addition, the resources that exist mostly focus on immigration from Mexico and Latin America. Immigration from Asia has been a major portion of immigrants to the United States especially since 2000. Immigrants from China, India, the Philippines, Vietnam, Laos, Cambodia, South Korea, Bangladesh among many other nations are not a monolith. Some came under visas designed to attract immigrants for specific professional jobs while others are refugees fleeing civil war or repressive governments. Economic hardship in their home countries was also a “push” factor. These immigrants have settled in many different areas in the United States as well changing communities in a variety of ways as immigrants have always done. This is a nuanced history and in this guide students will examine primary sources consisting of photographs from the communities where immigrants from Asia have settled in the United States. Using close analysis students will find patterns and themes so that they better understand the impact and contributions of this growing segment of immigrants. 

Hook/Bellringer

Post the following question on the board: According to the American Immigration Council there are 44.9 million immigrants (foreign-born individuals) living in the United States, can you guess the top five countries these individuals come from?

This could be set up via a number of online quiz tools like Kahoot or just on the white board with paper obscuring the answers. An unlabeled bar graph indicating the percentages below would work well too. 

Provide students with a “bank” of possible countries. Such as Germany, Italy, Brazil, China, Russia, Mexico, Argentina, Cuba, India, Nigeria, Egypt, Philippines, Australia, El Salvador.  

1. Mexico (24 percent of immigrants)
2. India (6 percent)
3. China (5 percent)
4. Philippines (4 percent)
5. El Salvador (3 percent)

Give the students a chance to guess and reveal answers as they are named. If they can not name all of them, give them 5 or so chances, and then reveal the rest of the answers. 

Note that after Mexico the next three countries of origin are Asian countries. It might also be helpful to point these countries out on a map. 

Brief discussion: What about this list surprises you? Are there countries that are higher than you thought? Lower? 

Inform the class that immigration from Asia has been increasing as a percentage of overall immigration to the United States. It wasn’t until the 2000s that more than one Asian country was even a top ten country of origin for immigrants to the U.S. In the next activity they will learn more about how immigration from Asia has changed the United States. 

Primary Source Analysis - Community Connections

The primary sources below are all photographs that depict Asian immigrant communities in the United States. They include photos of people engaged in a wide variety of activities including playing cards, selling and buying clothes, getting a haircut, playing chess, buying food, celebrating, socializing. There are also a variety of buildings including markets, restaurants, houses of worship, clothing stores, nail salons, laundromats, pharmacies, hardware stores and more. Together they provide a glimpse into the variety of ways individuals from the largest continent on earth have made their homes in the United States. The goal of engaging with these sources is for students to make connections between the activities that occur in their communities with what they see in these photographs of immigrant communities. 

1. Make the photos available to students either through links or by printing them out and arranging at different stations in the classroom. 
2. Have students select three photographs and complete the Primary Source Analysis Tool for each. [A Library of Congress Teacher’s Guide for analyzing photographs can be found here.]  Further tips for examining sources:
   1. Encourage students to slow down and examine the photos carefully
   2. Zoom in on the photos and take note of details. 
   3. What words do they see - either in English or another language?
   4. What products are for sale in the stores?
   5. Are there people in the photos? What do they appear to be doing?
3. Once they’ve completed their 3 analysis sheets, put them in pairs and small groups. Working together they will come up with connections between the photos and their own communities. Encourage students to think creatively. There might not be a Hindu temple in their community, but what places of worship are there? People might not gather to play cards, but what do they do for leisure and to socialize? Have one student per group compile a list of these Community Connections. 
4. After working in their groups for 15 minutes, the groups can share out with the class the connections they made. 

Primary Sources

 Kim, a Korean immigrant, showing a suit to Michael, Jinny's, Broadway, Gary, IN | Library of Congress | www.loc.gov/item/2022650724/

Vietnamese immigrants playing cards outside Tan Phat Noodle House, 3301 Westfield Ave., Camden, NJ 2015 | Library of Congress | www.loc.gov/item/2020698722/

Hookah lounge in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. Hookah lounges are places where patrons share communal hookahs, or water pipes | Library of Congress | www.loc.gov/item/2020722865/

A Middle Eastern-themed interior design shop in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis | Library of Congress | www.loc.gov/item/2020722860/

A barber named Hani gives a customer, Ali, (both gave only their first names) a haircut in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis | Library of Congress | www.loc.gov/item/2020722862/

Store in Hamtramck, Michigan, selling clothing, including burqas, or enveloping outer garment worn by women in some Islamic traditions. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis | Library of Congress | www.loc.gov/item/2020722864

Nail-care shop in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. In 2015, its city council became the first city council in the United States with a majority of the members of the Muslim faith | Library of Congress| www.loc.gov/item/2020722863/

The Makka Hi Fruit Market in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. In 2015, its city council became the first city council in the United States with a majority of the members of the Muslim faith | Library of Congress | www.loc.gov/item/2020722869/

A colorful tire shop in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. In 2015, its city council became the first city council in the United States with a majority of the members of the Muslim faith | Library of Congress | www.loc.gov/item/2020722824/

The Al-Qamar pizza parlor in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. In 2015, its city council became the first city council in the United States with a majority of the members of the Muslim faith | Library of Congress |  www.loc.gov/item/2020722826/

Burk's Igloo ice-cream stand in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. In 2015, its city council became the first city council in the United States with a majority of the members of the Muslim faith - original digital file | Library of Congress |  www.loc.gov/resource/highsm.60598/

Masjidun-Nur, a Muslim place of worship in Hamtramck, Michigan. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. In 2015, its city council became the first city council in the United States with a majority of the members of the Muslim faith | Library of Congress | www.loc.gov/item/2020722828/

Clothing store in Hamtramck, Michigan. Note the welcoming sign in three languages in the window. Known in the 20th century as a vibrant center of Polish-American life and culture, Hamtramck has continued to attract immigrants, especially Yemenis and Bangladeshis. In 2015, its city council became the first city council in the United States with a majority of the members of the Muslim faith | Library of Congress | www.loc.gov/item/2020722866/

Crivijit, originally from India, working for Uber, Myrtle Ave. at Wyckoff Ave., Brooklyn | Library of Congress | www.loc.gov/item/2021653446/ 

The Hindu Temple and Cultural Center, near the town of Madrid in Boone County, Iowa | Library of Congress |  www.loc.gov/item/2016630539/

One of several elaborate carvings outside the Hindu Temple and Cultural Center, near the town of Madrid in Boone County, Iowa | Library of Congress | www.loc.gov/item/2016630538/

The OK Boss Asian grocery stores in Windom, Minnesota. As of 2020, Asian restaurants and stores proliferated in small, southern Minnesota towns | Library of Congress | www.loc.gov/item/2020723773/

Chinese food shops in the Lakewood neighborhood, Chicago, Illinois | Library of Congress | www.loc.gov/resource/afc1981004.145/?sp=1

Yoga studio in the Lakewood neighborhood, Chicago, Illinois | Library of Congress | www.loc.gov/resource/afc1981004.145/?sp=11

 Chinese women playing cards. Bayard St. and Baxter St., Chinatown, Manhattan | Library of Congress |  www.loc.gov/item/2022642962/

Elderly men playing Chinese chess. Columbus Park, Bayard St., Chinatown, Manhattan | Library of Congress | www.loc.gov/item/2022885526/

Jolllybee, Filipino Restaurant, 609 8th Ave., Manhattan | Library of Congress | www.loc.gov/item/2021643708/

Filipino street vendors, 67-12 Roosevelt Ave., Queens | Library of Congress | www.loc.gov/item/2022885550/

Baptism celebration, Kabayan Bistro, a Filipino Lounge, 6909 Roosevelt Ave., Queens | Library of Congress | www.loc.gov/item/2024696323/

The Fil Am float, representing the Filipino American Association of Portland & Vicinity, Inc., passes by in the Fred Meyer Junior Parade, one several events in Portland, Oregon's, annual Rose Festival | Library of Congress | www.loc.gov/item/2018699497/

Vietnamese laundromat and Pizzeria, Saunders St. at N. 27th St., Camden, NJ, 2023 | Library of Congress |  www.loc.gov/item/2024695773/

Vietnamese laundromat and Mexican Taqueria, Saunders St. at N. 27th St., Camden NJ, 2006 | Library of Congress |  www.loc.gov/item/2020702024/

Korean musicians, Broad St. at Market St., Newark, NJ | Library of Congress | www.loc.gov/item/2021635295/

Entrance sign at the Assi Plaza Asian grocery and Korean and Chinese specialty store in the Flushing neighborhood of the New York City borough, or county-like jurisdiction, of Queens | Library of Congress | www.loc.gov/item/2018701181/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699994/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699995/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699996/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699997/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699998/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress |  www.loc.gov/item/2018700000/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018700001/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699941/

Fish market in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699985/

Produce stand in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699986/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699987/

Scene in Lower Manhattan's Chinatown neighborhood in New York City | Library of Congress | www.loc.gov/item/2018699988/

Some of the hundreds of participants at the 10th-annual Hmong New Year Celebration in downtown Chico, California, pose | Library of Congress | www.loc.gov/item/2013631121/

General Tips for Teaching Controversial Subjects

• Center activities on primary sources. Primary sources are tangible evidence that allow students to engage directly with history. These primary sources in particular were preserved and digitized by the Library of Congress because they were deemed important to the history of the United States.
• Discussion and analysis of these sources can be wide ranging, but within each class those discussions can always be turned back to the source itself.
• The sources are also, by definition, only pieces of a puzzle. They bring us closer to understanding the past but there is always room for doubt and uncertainty.  
• Questions, Observations, and Reflections should come from students. These are primarily student-directed learning activities. It is the instructor's role to create a space for inquiry and empower students to drive the inquiry.
• It may help to remind students at the outset that it is normal for different individuals to come to different conclusions, even when we are looking at the same sources. Further, it would be strange if we all agreed completely on our interpretations. This can normalize the strong reactions that can come up and enables educators to discuss the goal of historical research, which is to hopefully go beyond the realm of individual  perspective to access a fuller understanding of the past that takes multiple perspectives into account.
• Teaching historical topics that involve violence and other trauma can be traumatic for some students as well. Providing students with previews of what content will be covered and space to process their emotions can be helpful. The following video series from the University of Minnesota contains further tips for teaching potentially traumatic topics: https://extension.umn.edu/trauma-and-healing/historical-trauma-and-cultural-healing.

What is it?

Women’s suffrage is a commonly-taught topic in U.S. history and the textbook narrative follows a familiar pattern: the topic often begins with Seneca Falls in 1848 and ends with the ratification of the 19th Amendment in 1920. While these were both important events, one way historians ask new questions about the past is by asking whether a topic’s generally accepted beginning and ending are actually the most useful for understanding the topic. Historians call this “periodization”. Sometimes it’s useful to include what happened before the time period and sometimes it's useful to consider what happened later. Along these lines, historians of women's suffrage like Cathleen Cahill have researched the contributions of Black women, Native women, and other women of color to the cause of women's suffrage. In Dr. Cahill’s book Recasting the Vote: How Women of Color Transformed the Suffrage Movement, she notes that for many of these women the ratification of the 19th amendment was a step toward getting the right to vote but it was not sufficient to allow all women to vote. Additional obstacles included Jim Crow laws in the South that disenfranchised Black and Mexican women, federal laws that made Native people wards of the state, and immigration laws that prevented Chinese women from becoming citizens. By pulling back and considering a longer period of time, students and teachers can see the broader movement to secure the vote and better understand the history of suffrage.

Key points:

• The activity outlined here will take one 90-minute period or two 45-minute periods. It is appropriate for a high school U.S. history classroom, but can be modified for a variety of learners.
• Students will analyze, interpret, and evaluate primary sources.
• Students will learn about how not all women received the right to vote with the 19th amendment and how Native, Black, Latin American, and Asian women both participated in the struggle for suffrage and incorporated that struggle into efforts to gain rights for their communities.

Approach to Topic

Examining women’s suffrage through the contributions of Native, Black, Latin American, and Asian women not only provides a fuller and more inclusive account of this important event in U.S. history, it also adds to students’ understanding of the history of race in the United States. For example, in the case of Native Americans, their depiction in U.S. history textbooks too often suffers from what Native scholar Vine Deloria, Jr., called “the ‘cameo’ theory of history” where Native people briefly appear “on stage” only to then disappear from a narrative that is centered around the activities of European Americans. By incorporating Native people throughout our study of U.S. history, we can avoid this “cameo” effect and communicate to students that Native people have been a part of American history from the beginning to the present day. For other people of color too in U.S. history, their actions and activities are often only touched upon in textbook sections that are isolated from the rest of U.S. history. For every major event in U.S. history, a wide variety of Americans from different racial backgrounds participated, often in important roles.  As Cahill writes, on these suffragist activists:

Their political awakenings emerged from their engagement with the concerns of their own communities as well as their anti-racist activism, fights for justice, and struggles for sovereignty and nation-building. They saw the campaign for women’s right to vote as addressing some of the specific concerns of their communities; they also
saw it as a means of finding allies in other causes.

Cahill highlights the 1913 Suffrage Parade in Washington, DC as an event that brought together women suffragists from a variety of backgrounds to advocate for the vote. The parade took place on March 3, 1913, the day before President Woodrow Wilson’s inauguration. Have students read this summary from the National Park Service about the 1913 parade: https://www.nps.gov/articles/woman-suffrage-procession1913.htm

When they are done, ask the class:

• What was the parade trying to accomplish?  
• How did they group themselves?
• What obstacles did the marchers face?
• How were Black and Native women were represented in the parade?  

Primary source activity

Provide students with links to the primary sources below. Ask them to choose one of the sources, and add to their responses to the questions above with observations about their source.

1913 Suffrage Parade
Primary sources:
Official program woman suffrage procession. Washington, D. C. March 3, 1913. | Library of Congress
https://www.loc.gov/item/rbpe.20801600/

Head of suffrage parade in Washington, D.C., Mar. 3, 1913 | Library of Congress
https://www.loc.gov/item/97500042/

“Fifteen Thousand Women to March for Suffrage,” The sun. [volume] (New York [N.Y.]), 28 April 1912. Chronicling America: Historic American Newspapers. Lib. of Congress. <https://chroniclingamerica.loc.gov/lccn/sn83030272/1912-04-28/ed-1/seq-57/> (Mentions Mabel Lee)

"Home Makers," Suffrage Parade | Library of Congress
https://www.loc.gov/item/2014691447/

[College section of the March 3, 1913, suffrage parade in Washington, D.C.] | Library of Congress
https://www.loc.gov/item/mnwp000444/

Woman suffrage parade, Wash., D.C. | Library of Congress
https://www.loc.gov/item/2013648100/

Pro-Suffrage Activists
Below are profiles of women’s suffrage reformers who marched in the 1913 parade. These women wanted the 19th amendment to pass and for restrictions on women voting to end, but that was not enough to secure the vote for all of them. As a result, their activism did not end in 1920. Along with each reformer is a brief biographical sketch that details causes for which the individuals advocated before and after 1920.. Each profile also contains several primary sources for students to examine so they can learn more about the individual.

Marie Louise Bottineau Baldwin

Marie Louise Bottineau Baldwin was born in 1863 on Ojibwe land in present-day North Dakota. She attended public schools in Minnesota and eventually graduated from Washington College of law. Baldwin used her status as a lawyer to advocate for Native issues. From 1904 to 1932 she worked for the U.S. federal government’s Office of Indian Affairs overseeing government contracts to reservations. She joined the Society of American Indians after it was formed in 1911. When the 19th Amendment was ratified in 1920, Native women like Baldwin were not automatically granted the right to vote as they were not considered U.S. citizens.

Primary Sources
Mrs. Marie L. Baldwin ,1914
https://www.loc.gov/item/2014697070/

Mrs. Marie L. Baldwin, 1914
https://www.loc.gov/item/2014697069/

GRETCHEN SMITH, “INDIAN COLLECTION WORK OF 30 YEARS: Mrs. Baldwin, Chippewa,” The Evening Star, April 15, 1929
https://chroniclingamerica.loc.gov/lccn/sn83045462/1929-04-15/ed-1/seq-7/

Gertrude Simmons Bonnin/ Zitkála-Šá

Zitkála-Šá (pronounced Zeet-KA-la-sha) was born on the Yankton Indian Reservation in South Dakota in 1876. A Yankton Dakota Sioux, Zitkála-Šá like many thousands of Native children at the time was also forced to attend a boarding school far away from her home. At eight years old, Zitkála-Šá left Yankton and her family to attend the Indiana Manual Labor Institute in Wabash, Indiana over 700 miles away.

In her life, Zitkála-Šá rose to prominence as a musician, writer, and political advocate. An accomplished violinist, she performed at the White House for President William McKinley in 1900 and as a soloist at the Paris Exposition that same year. A prolific writer, Zitkála-Šá’s presented depictions of American Indians that emphasized family and community in books such as American Indian Stories and presented her own experiences in personal essays for Harper’s Monthly and The Atlantic Monthly. When the 19th Amendment was ratified in 1920, Native women like Zitkála-Šá were not automatically granted the right to vote as they were not considered U.S. citizens.

Primary Sources
“She is Watching Congress,” Evening Public Ledger, February 22, 1921 https://chroniclingamerica.loc.gov/lccn/sn83045211/1921-02-22/ed-1/seq-20/

“Sioux Princess Closely Watches Indian Welfare,” The Richmond Palladium and Sun-Telegram, February 26, 1921 https://chroniclingamerica.loc.gov/lccn/sn86058226/1921-02-26/ed-1/seq-15/

Maryland Suffrage Sews, June 15, 1918
https://chroniclingamerica.loc.gov/lccn/sn89060379/1918-06-15/ed-1/seq-5/

Carrie Williams Clifford

Carrie Williams Cliffordwas born and raised in Ohio. She graduated from an integrated high school in Columbus, Ohio and worked as a teacher and for her mothers hair styling business. Clifford published two books of poetry, Race Rhymes and The Widening Light. 

Clifford helped found the Ohio State Federation of Colored Women in 1900 and served as its first president. She advocated for the rights of women and for the rights of Black people. A close friend of W.E.B. Du Bois, Clifford recruited Black women to join the Niagara Movement, the organization that would become the National Association for the Advancement of Colored People (NAACP) in 1912. Four years after participating in the Suffrage Parade in Washington, Clifford marched with the NAACP in New York City in what was known as the “Silent Protest Parade” on July 18, 1917. The demonstration protested against violence against Black Americans, specifically the East St. Louis Massacre earlier that month. Clifford wrote a poem to commemorate the march: https://scalar.lehigh.edu/harlemwomen/silent-protest-parade After the ratification of the 19th Amendment, Clifford would have been able to vote in her native Ohio, but in many southern states Jim Crow laws effectively prevented Black men and Black women from voting until the 1960s.

Primary Sources:

“Mrs. Carrie Clifford Spoke Right Out in Meeting,” The broad ax. [volume] (Salt Lake City, Utah), 02 Sept. 1905. Chronicling America: Historic American Newspapers. Lib. of Congress. <https://chroniclingamerica.loc.gov/lccn/sn84024055/1905-09-02/ed-1/seq-1/>

(image)“Author of Rare Book of Poems,” Franklin's paper the statesman. (Denver, Colo.), 13 Jan. 1912. Chronicling America: Historic American Newspapers. Lib. of Congress. <https://chroniclingamerica.loc.gov/lccn/sn91052311/1912-01-13/ed-1/seq-6/>

(image) “Mrs. Clifford Reelected,” The colored American. [volume] (Washington, D.C.), 13 Aug. 1904. Chronicling America: Historic American Newspapers. Lib. of Congress. <https://chroniclingamerica.loc.gov/lccn/sn83027091/1904-08-13/ed-1/seq-14/>

Carrie Williams Clifford, “Marching to Conquest,” 1911

Marching to Conquest

We are battling for the right with purpose strong and true;
'Tis a mighty struggle, but we've pledged to dare and do;
Pledged to conquer evil and we'll see the conflict thro'
Marching and marching to conquest.

All the noble things of life we'll teach our girls and boys,
Warn them of its pitfalls and reveal its purest joys,
Counsel, guide and keep them from the evil that destroys
As we go marching to conquest.

Loving confidence and trust must mark our intercourse,
Harmony and unity will our success enforce ;
Seeking guidance from the Lord of good, the boundless source,
As we go marching to conquest.

Come and join our anthem then and raise a mighty shout,
Sing it with such fervor as will put our foes to rout,
Sing it with conviction strong, dispelling every doubt,
As we go marching to conquest.

Women, when our work is o'er and we to rest have gone.
May our efforts doubled, trebled, still go sweeping on.
And the voices of millions swell the volume of our song.
As they go marching to conquest.

Chorus :
Hurrah, hurrah, we'll shout the jubilee;
Hurrah, hurrah, we'll set the captives free,
Ignorance, distrust and hate at our approach shall flee.
  Marching and marching to conquest.

Nina Otero-Warren

Nina Otero-Warren was born to a wealthy and prominent Spanish-speaking family in present-day New Mexico in 1881. College educated, Otero-Warren was briefly married to U.S. army officer Rawson Warren, but they divorced after two years. She never remarried and instead became an important figure in local politics in Albuquerque for over 50 years. In 1917, she became the head of the New Mexico chapter of the Congressional Union, which would become the National Woman’s Party. Otero-Warren pushed the party to publish suffrage literature in Spanish as well as English to reach the largest number of people in the American Southwest. From 1918 to 1929, Otero-Warren served as the Superintendent of Public Schools in Santa Fe County and in this role resisted efforts to impose English-only education and also publicly criticized the conditions of the county’s Indian boarding schools. 

In 1921, only a year after the 19th Amendment was ratified, Otero-Warren ran for Congress. She won the Republican nomination for the U.S. Representative, but lost in what was a close election.

Primary Sources

Adelina Otero-Warren | Library of Congress

https://www.loc.gov/item/2014716277/

“Mrs. Otero-Warren Equipment for Service in the U.S. Congress,” The Clayton news. (Clayton, N.M.), 27 Oct. 1922. Chronicling America: Historic American Newspapers. Lib. of Congress. <https://chroniclingamerica.loc.gov/lccn/sn93061573/1922-10-27/ed-1/seq-4/>

“Picturesque Family History Adds Interest to Race for Congress by Mrs. Otero-Warren.” The Clayton news. (Clayton, N.M.), 29 Sept. 1922. Chronicling America: Historic American Newspapers. Lib. of Congress. <https://chroniclingamerica.loc.gov/lccn/sn93061573/1922-09-29/ed-1/seq-4/>

Mabel Ping-Hua Lee

Mabel Ping-Hua Lee was born in Guangzhou, China in 1897. When Lee was nine-years-old, she won an academic scholarship to study in New York City where her father, a missionary, was already living. Living in Chinatown and attending school at the Erasmus Hall Academy in Brooklyn, Lee became involved with activism as a teenager participating, on horseback, in her first suffrage parade in 1912. Lee attended Barnard College and wrote essays for the college’s The Chinese Students’ Monthly one of which was titled “The Meaning of Woman Suffrage.” When the 19th Amendment was ratified, Lee herself was not still able to vote because the Chinese Exclusion Act of 1882 prevented any Chinese person from becoming a U.S. citizen. Lee earned her PhD in economics from Columbia University and published an economic history of China in 1921.  

Primary Sources
“Chinese Girl Wants to Vote,” New-York tribune. [volume] (New York [N.Y.]), 13 April 1912. Chronicling America: Historic American Newspapers. Lib. of Congress. <https://chroniclingamerica.loc.gov/lccn/sn83030214/1912-04-13/ed-1/seq-3/>

Mabel Ping-Hua Lee, Excerpt from “The Meaning of Woman Suffrage” The Chinese Student Monthly, Barnard College, May 1914.

I once heard Professor Kirchway of Columbia say that although scientists are always
telling us that in the midst of life we are in death, we are not as apt to realize it as
much as that while in the midst of life we are in the woman suffrage question. And it
is a fact that no matter where we go we cannot escape hearing about woman
suffrage. Yet there is hardly a question more misunderstood or that has more
misapplications. So manifold are its misconceptions that it has come to be a by-­‐word
suitable for every occasion. For instance, if when in company one should wish to
scramble out of an embarrassing situation, or his more fortunate brother should
wish to be considered witty, all that either would have to do would be to mention
woman suffrage, and they may be sure of laughter and merriment in response.

The reason for this is that the idea of woman suffrage at first stood for something
abnormal, strange and extraordinary, and so has finally become the word for
anything ridiculous. The idea that women should ever wish to have or be anything
more than their primitive mothers appears at first thought to be indeed tragic
enough to be comic; but if we sit down and really think it over, throwing aside all
sentimentalism, we find that it is nothing more than a wider application of our ideas
of justice and equality. We all believe in the idea of democracy; woman suffrage or
the feminist movement (of which woman suffrage is a fourth part) is the application
of democracy to women.

Suggested activity: Reframe the story
After students have read through the textbook account of women’s suffrage, distribute the sources and brief biographical sketches of the women’s suffrage reformers listed above. Prompt the students to take special note of each reformer’s activities before and after the ratification of the 19th amendment in 1920. Place them in groups where each group has a mix of students who learned about a different reformer. In groups, have them draft new text for a textbook entry on women's suffrage that provides a new timeline for the topic. Questions they should consider as they write their entry:

• What dates are the most important to emphasize? Do they need a timeline to communicate the order of events?
• What primary sources should they use as part of the text?
• What should the title of their textbook section be?

General Tips for Teaching Controversial Subjects

• Center activities on primary sources. Primary sources are tangible evidence that allow students to engage directly with history. These primary sources in particular were preserved and digitized by the Library of Congress because they were deemed important to the history of the United States.
• Discussion and analysis of these sources can be wide ranging, but within each class those discussions can always be turned back to the source itself.
• The sources are also, by definition, only pieces of a puzzle. They bring us closer to understanding the past but there is always room for doubt and uncertainty.  
•  Questions, Observations, and Reflections should come from students. These are primarily student-directed learning activities. It is the instructor's role to create a space for inquiry and empower students to drive the inquiry.
•  It may help to remind students at the outset that it is normal for different individuals to come to different conclusions, even when we are looking at the same sources. Further, it would be strange if we all agreed completely on our interpretations. This can normalize the strong reactions that can come up and enables educators to discuss the goal of historical research, which is to hopefully go beyond the realm of individual  perspective to access a fuller understanding of the past that takes multiple perspectives into account.
• Teaching historical topics that involve violence and other trauma can be traumatic for some students as well. Providing students with previews of what content will be covered and space to process their emotions can be helpful. The following video series from the University of Minnesota contains further tips for teaching potentially traumatic topics: https://extension.umn.edu/trauma-and-healing/historical-trauma-and-cultural-healing.