[4]: 36  The Chinese Exclusion Act, as noted by Erika Lee, is remarkable for "establish[ing] Chinese—categorized by their race, class, and gender relations as the ultimate category of undesirable immigrants—as the models by which to measure the desirability (and "whiteness") of other immigrant groups".

[4]: 37  It is precisely this metric of "whiteness" which would be contested in dozens of court cases asserting the right of immigrants who did not fit neatly into a black/white racial schema to naturalize.

Henry Smith, the same presiding District Judge who had ruled a year earlier in Ex Parte Shahid denied Dow's application for citizenship based on a rejection of the "scientific evidence" that Syrians are Caucasian.

[7]: 6  While the Judge admits that, unlike in the case of Ex Parte Shahid, the applicant had, "performed all the necessary formalities and would apparently from his intelligence and degree of information of a general character be entitled to naturalization",[7]: 1  he ultimately rejects Dow's petition for naturalization based on the fact that, "the applicant is not that particular free white person to whom the act of Congress has donated the privilege of citizenship in this country with its accompanying duties and responsibilities".

[7]: 9 Following the ruling in Ex Parte Dow, members of Charleston, South Carolina's Syrian population organized fundraising and awareness campaigns to raise support for a judicial appeal.

[8]: 4  District Judge Henry Smith again demurred from this line of reasoning based on the assumption that "White persons", to the average citizen of the United States in 1790, would have meant Europeans.

it seems to be true beyond question that the generally received opinion was that the inhabitants of a portion of Asia, including Syria, were to be classed as white persons", thereby overturning the lower court's decision to deny George Dow's application for US citizenship.

The US Supreme Court did not rule on the racial classification of Syrians or Arabs generally during the era when categorization as white was important in immigration law.

In the 1942 case In re Ahmed Hassan, a district court judge in Michigan noted that a Yemenite immigrant was dark-skinned and found him ineligible for naturalization because the Arabian Peninsula was far from Europe, not even bordering the Mediterranean and part of the "Mohammadan World".