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Tsui Kwo Yin's letter of April 12, 1892 to Secretary Blaine outlined his opposition to the Geary Act by showing that the Exclusion Act of 1882 created 32,000 more departures than arrivals in San Francisco from 1882 to 1891. Tsui Kwo Yin wrote that the Geary Act violated treaty obligations and was unnecessary.

Tsui Kwo Yin did not see that the Exclusion Act was becoming less effective from 1882 to 1888. The District Court for the Northern District of California, San Francisco maintained an index of habeas corpus cases. From 1882 to 1889 the overwhelming majority of the detainees were discharged and allowed to remain in the United States. In 1887 and 1888, more Chinese arrived than departed, and more detainees were discharged than remanded. The 1882 Exclusion Act was not able to restrict immigration enough to satisfy the Congress. The Scott Act and Geary Act were passed to limit further Chinese immigration.

March 30, 1892 Customs-House, San Francisco, T. C. Phelps, Collector
from the M98, Roll 3, Notes from the Chinese Legation in the United States of Department of State

Image from Volume 57, San Francisco, California Historical Society Quarterly