rred Chinese from naturalization on the grounds that they and other Asians could not be assimilated into American society. Unable to become citizens, Chinese immigrants were prohibited from voting and serving on juries, and dozens of states passed alien land laws that prohibited non-citizens from purchasing real estate, thus preventing them from establishing permanent homes and businesses. The idea of an "unassimilable" race became a common argument in the exclusionary movement against Chinese Americans. In particular, even in his lone dissent against Plessy v. Ferguson (1896), then-Supreme Court Justice John Marshall Harlan wrote of Chinese people as: "a race so different from our own that we do not permit those belonging to it to become citizens of the United States. Persons belonging to it are, with few exceptions, absolutely excluded from our country. I allude to the Chinese race." In 1873, the Pigtail Ordinance targeted Qing dynasty immigrants' largely mandatory queue hairstyle which intended to reduce Qing immigration by banning their hairstyle which they must have to enable customary later re-entry to China. The city board passed it but the mayor vetoed it. The city council enacted it in 1876 but was struck down as unconstitutional in 1879. In the US, xenophobic fear of the alleged "Yellow Peril" led to the implementation of the Page Act of 1875 which excluded Chinese women from entering the US per yellow peril and dragon lady stereotypes, the 1882 Chinese Exclusion Act, expanded ten years later by the Geary Act which required Chinese to register and secure a certificate as proof of entry at risk of deportation or har