Roldan v. Los Angeles County

Roldan v. Los Angeles County, 129 Cal. App. 267, 18 P.2d 706, was a 1930s court case in California confirming that the state's anti-miscegenation laws at the time did not bar the marriage of a Filipino and a white person.^[1] However, the precedent lasted barely a week before the law was specifically amended to illegalize such marriages.^[2]

Background

The case involved a

Mongolian race".^[7] In 1930, a court had denied another Filipino man, Tony Moreno, permission to marry his white fiancée and ruled that Filipinos and other "Malayans" were part of the "Mongolian race" and thus not eligible to marry whites.^[8]

However, the following year, Judge Walter Guerin granted a marriage licence for Gavino Visco to marry Ruth M. Salas. The groom was a

Superior Court of Los Angeles County. Judge Walter Gates granted the writ.^[5]

Appeals

County counsels L. E. Lampton and Everett Mattoon appealed Gates' decision to the

late 19th century influx of Chinese immigrants.^[9] The court thus concluded that Filipinos were members of the "Malay race" and not the "Mongoloid race", finding Roldan and Rogers' marriage legal.^[6]

County officials appealed the case again to the Supreme Court of California in 1933.^[6] On March 27, 1933, the Supreme Court announced that it would not review the case, effectively upholding the appellate court's decision.^[9] Soon after that announcement, the California State Legislature voted to amend Civil Code Section 60 to ensure that the law against interracial marriage also covered "members of the Malay race".^[10] California Governor James Rolph signed the amendment into law on April 5, 1933.^[2]